Mazen v. Board of Regents of Regency Universities of Illinois

789 F. Supp. 954, 1992 WL 84962
CourtDistrict Court, C.D. Illinois
DecidedApril 15, 1992
DocketNo. 89-3100
StatusPublished

This text of 789 F. Supp. 954 (Mazen v. Board of Regents of Regency Universities of Illinois) is published on Counsel Stack Legal Research, covering District Court, C.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mazen v. Board of Regents of Regency Universities of Illinois, 789 F. Supp. 954, 1992 WL 84962 (C.D. Ill. 1992).

Opinion

OPINION

RICHARD MILLS, District Judge:

A question of retroactivity.

In 1989, Plaintiff filed this suit pursuant to the Civil Rights Act of 1964.

This case was placed on the Court’s trial calendar beginning September 3, 1991, but was continued until December in order to accommodate an expert witness who was out of the country.

[955]*955On November 21, 1991, the President of the United States signed into law the Civil Rights Act of 1991, which amended the Civil Rights Act of 1964 and 42 U.S.C. § 1981.

May Plaintiff amend his complaint under the Civil Rights Act of 1991 to reinstate Defendants which have already been dismissed as parties by this Court?

No!

To do so would result in manifest injustice.

I. FACTS

Plaintiff is an Egyptian-born professor who joined the Illinois State University’s (I.S.U.) faculty in 1981 as a member of the Department of Management and Marketing. Professor Mazen’s first contract was for a temporary position for the 1981-82 academic year. Subsequently, he was rehired for a second year on the “tenure track” with 1988 as the projected year of tenure. From 1982 through 1987, he was employed through a series of contracts, each covering the nine month academic year.

Prof. Mazen’s evaluations for the time period between 1981 and 1986 ranged from “exceptional and outstanding” to “exceptional merit” to “merit.” He was also nominated for the college research award and the college best teacher award.

In 1985, the Department of Management and Marketing split and the Management group became the Department of Management and Quantitative methods. Also during this time the Department had four different chairs.

In 1987, Prof. Mazen was twice accused of violating I.S.U.’s ethical code. On the first occasion, he was summoned to meet with the Department Faculty Status Committee (DFSC) concerning two articles which had been accepted for publication in 1986. At the meeting, he was informed that neither of the two articles would be considered in his promotion and tenure decision because “the methodology of the two' articles was quite similar.” The DFSC also questioned Prof. Mazen’s junior co-authors. The DFSC allegedly reversed its position and recognized the two articles when Prof. Mazen and his co-authors threatened legal action for the false ethical accusations.

Subsequently, Prof. Mazen received only a “merit” evaluation for his previous year’s work. Also, the DFSC recommended denial of tenure and promotion citing as a basis a statistical analysis performed on Prof. Mazen’s student evaluations and his incompetence in all areas, including teaching, research and service. In addition, he was accused a second time of violating the ethics code for an incident in 1985 in which a colleague had raised a question concerning the manner in which Prof. Mazen had listed a publication on his curriculum vitae. This was the first time that Prof. Mazen was made aware of the 1985 accusation because the 1985 committee had not considered the issue significant.

The DFSC’s recommendations were forwarded to the College Faculty Status Committee (CFSC) and ultimately to the University Appeals Committee (UAC), both of which concurred with the denial of tenure and promotion.

Prof. Mazen appealed and an informal meeting was held with himself, the DFSC, the CFSC and the Department Chair. During this meeting one of Prof. Mazen’s colleagues, Prof. Graeff, pointed angrily at Prof. Mazen and stated that the treatment Prof. Mazen had received was no worse than what Prof Graeff had been subjected to during his tenure proceedings presided over by the former department chair, Dr. Halim, who was also of Egyptian birth.

On April 30, 1987, I.S.U.’s Provost sent a letter to Prof. Mazen informing him that he would not be promoted to Associate Professor or granted tenure and that he would not be reappointed to a faculty position at I.S.U. following the 1987-88 academic year.

Consequently, Prof. Mazen filed a charge of discrimination with the Equal Employment Opportunity Commission, received his notice of his right to sue, and commenced this action on May 1, 1989. His amended complaint consisted of three counts: Count I alleged that I.S.U. discriminated against him on the basis of national origin in viola[956]*956tion of Title VII, 42 U.S.C. § 2000e-2(a); Count II was brought pursuant to § 1983 against I.S.U.’s Provost and five other Defendants who took part in the recommendation denying Prof. Mazen’s tenure and promotion; and Count III was brought against the same Defendants listed in Count II and alleged a violation of Prof. Mazen’s liberty interests.

On May 14, 1990, this Court allowed the Defendants’ motion to dismiss Count III pursuant to Fed.R.Civ.P. 12(b)(6) and on September 3,1991, this Court granted summary judgment in favor of the five Defendants listed in Count II. Thus, this action proceeded with only Prof. Mazen and I.S.U. as parties.

Prof. Mazen now seeks to amend his complaint under the Civil Rights Act of 1991 by adding Counts V and VI against the same Defendants previously named in Counts II and III. Specifically, Count V is brought pursuant to 42 U.S.C. § 1981 and alleges that the Defendants violated Prof. Mazen’s contractual rights. Count VI alleges that Defendants denied him equal protection of the laws in violation of 42 U.S.C. § 1983.

He seeks compensatory and punitive damages on each count and demands a jury trial.

II. ANALYSIS

The United States Supreme Court has provided lower courts with two conflicting lines of authority for determining the re-troactivity of statutes. In Bradley v. School Bd., 416 U.S. 696, 94 S.Ct. 2006, 40 L.Ed.2d 476 (1974), the Court approved “the principle that a court is to apply the law in effect at the time it renders its decision, unless doing so would result in manifest injustice or there is statutory direction or legislative history to the contrary.” Bradley, at 711, 94 S.Ct. at 2016. Fourteen years later, in Bowen v. Georgetown Univ. Hospital, 488 U.S. 204, 109 S.Ct. 468, 102 L.Ed.2d 493 (1988), the Court announced that “retroactivity is not favored in the law. Thus, congressional enactments ... will not be construed to have retroactive effect unless their language requires this result.” Bowen, at 208, 109 S.Ct. at 471.

The district courts which have considered the retroactivity of the 1991 act have reached their conclusions according to whether their Circuit prefers the Bowen or the Bradley line of cases. The Seventh Circuit Court of Appeals has applied both the Bradley and the Bowen decisions to the question of retroactivity.

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