Minnis v. Board of Supervisors of Louisiana State University & Agricultural & Mechanical College

972 F. Supp. 2d 878, 302 Educ. L. Rep. 1127, 2013 WL 5281173, 2013 U.S. Dist. LEXIS 133633
CourtDistrict Court, M.D. Louisiana
DecidedSeptember 18, 2013
DocketCivil Action No. 13-5-BAJ-RLB
StatusPublished
Cited by8 cases

This text of 972 F. Supp. 2d 878 (Minnis v. Board of Supervisors of Louisiana State University & Agricultural & Mechanical College) is published on Counsel Stack Legal Research, covering District Court, M.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Minnis v. Board of Supervisors of Louisiana State University & Agricultural & Mechanical College, 972 F. Supp. 2d 878, 302 Educ. L. Rep. 1127, 2013 WL 5281173, 2013 U.S. Dist. LEXIS 133633 (M.D. La. 2013).

Opinion

RULING AND ORDER

BRIAN A. JACKSON, Chief Judge.

Before the Court is Defendants’ Motion to Dismiss Complaint Pursuant to Rule 12(b)(6) (Doc. 8). Also before the Court is Defendants’ Supplemental Motion to Dismiss Complaint Pursuant to Rule 12(b)(6) (Doc. 21). Plaintiff, Anthony Minnis (“Plaintiff,” or “Minnis”), filed this lawsuit against the Board of Supervisors of Louisiana State University (“LSU”), as well as Miriam Segar, in her individual and official capacity as Senior Women’s Administrator of the Louisiana State University Athletic Department (“Segar”), Joseph Alieva, in his individual and official capacity as Athletic Director (“Alieva”), and Eddie Nunez, in his individual and official capacity as Associate Athletic Director (“Nunez”) (collectively, “Administrator Defendants”), after he was terminated from his position as Women’s Tennis Coach at LSU (Doc. 1). Minnis alleges various claims: impairment of contract on the basis of race in violation of 42 U.S.C. § 1981; various claims under 42 U.S.C. § 1983, including violations of Minnis’s rights under the First and Fourteenth Amendments.

BACKGROUND

LSU hired Minnis, a black male, as Head Coach of the Women’s Tennis Team in August 1991 (Doc. 1-2, at 1). In his 21 years a Head Coach, Minnis’s teams qualified for the NCAA Tournament 15 times (Doc. 1-2, at 2). He was chosen as Southwest Regional Women’s Tennis Coach of the Year five times, and SEC Coach of the Year once (Doc. 1-2, at 2). Minnis coached ten All-American1 tennis players during his time at LSU, including the SEC Player of the Year in 2001 and 2007 (Doc. 1-2, at 2). Throughout his tenure, Minnis’s student-athletes averaged over a 3.0 GPA and each athlete who remained in the program for four years graduated (Doc. 1-2, at 2).

[882]*882Minnis alleges he was subject to “unwelcome race-based harassment and discrimination,” including: 1) receiving an annual salary of up to $30,000 less than white coaches; 2) being “subjected to unjust evaluations and false letters of reprimand based on non-existent policies”; 3) false accusations against Minnis and “unfound[ed] write-ups (sic)”; and 4) treating similarly situated white persons more favorably than Minnis because of his race (Doc. 1-2, at 2). Minnis claims he reported, protested, and complained about this discrimination and harassment both verbally and in writing (Doc. 1-2, at 3). As an example of such discrimination, Minnis claims that, in February 2012, he requested from Segar the salaries of all head coaches and assistant coaches in the Southeastern Conference (“SEC”).2 Minnis alleges that the Administrator Defendants told him in response that he was “paid in proportion to all SEC Head Women’s Tennis coaches,” only to discover later on his own that he was the lowest paid Head Coach at LSU and at or near the bottom when compared to other SEC Head Women’s Tennis coaches (Doc. 1-2, at 3). When Minnis complained about this pay disparity, he claims the Administrator Defendants responded by giving him two ratings of “needs improvement,” and made threats to his continued employment (Doc. 1-2, at 3).

Minnis further alleges that, in addition to opposing discrimination based on race and harassment, he also “opposed inequitable treatment of Women’s Athletics at LSU and violations of Title IX” (Doc. 1-2, at 3). As a result of his protestations, Minnis claims he was “chastised” and “belittled” by Administrator Defendants, and threatened by Alieva that he would be terminated (Doc. 1-2, at 3).

Minnis was terminated from his position on June 30, 2012 (Doc. 1-2, at 3). Defendants Alleva, Segar, and Nunez were Minnis’s supervisors at the end of his tenure at LSU (Doc. 1-2, at 2). Minnis claims that, despite his requests, Administrator Defendants refused to provide a reason for his termination, which created a “cloud of suspicion” surrounding his termination (Doc. 1-2, at 3-4). In addition, Minnis claims that Administrator Defendants responded to reference inquiries about him by saying “he had issues,” which he claims was false and painted him in a false light, and caused him to be unable to secure new employment (Doc. 1-2, at 4). Finally, Minnis claims that he received no evaluation for the 2010-11 season prior to his discharge, in violation of LSU’s own policy, and that his replacement, a white female with “far less experience” is being paid substantially more than he was paid (Doc. 1-2, at 4).

Minnis filed suit against Defendants in state court on November 20, 2012, which Defendants removed to this Court on January 3, 2013 (Doc. 1). Minnis alleges the following causes of action: 1) impairment of his right to contract under 42 U.S.C. § 1981; 2) several claims under 42 U.S.C. § 1983, including violation of his right to “protest and oppose unlawful race-based and gender-based discrimination” guaranteed by the First Amendment, violation of his right to equal protection and liberty as provided by the Fourteenth Amendment; 3) claims for discrimination and retaliation based on race in violation of Title VII, 42 U.S.C. § 2000e; and 4) a claim for gender-based discrimination in violation of Title IX, 20 U.S.C. § 1681 (doc. 1-2, at 1-6). Minnis also alleges various claims under state law.

[883]*883Defendants now move to dismiss a variety of Minnis’s claims pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure (Doc. 8). Specifically, Defendants seek dismissal of the following claims: 1) all claims under § 1983 against LSU and against the Administrator Defendants in their official capacities; 2) all § 1981 claims as to all Defendants; 3) all claims under § 1983 against the Administrator Defendants in their individual capacities on the basis of qualified immunity; 4) all Title VII claims against the Administrator Defendants in their official and individual capacities; 5) all Title IX claims against Administrator Defendants in their official and individual capacities; and 6) all Title IX claims against all defendants for punitive damages (Doc. 8-1, at 14).

STANDARD OF REVIEW

In considering a Motion to Dismiss pursuant to Rule 12(b)(6), a court accepts as true all well-pleaded facts and views them in the light most favorable to the plaintiff. Baker v. Putnal, 75 F.3d 190, 196 (5th Cir.1996). However, a court is not bound to accept legal conclusions couched as factual allegations. Papasan v. Attain, 478 U.S. 265, 286, 106 S.Ct. 2932, 92 L.Ed.2d 209 (1986). The plaintiff must plead sufficient facts to state a claim for relief that is plausible on its face. Ashcroft v. Iqbal, 556 U.S. 662, 677, 129 S.Ct. 1937, 173 L.Ed.2d 868 (2009); Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570, 127 S.Ct. 1955, 167 L.Ed.2d 929 (2007).

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972 F. Supp. 2d 878, 302 Educ. L. Rep. 1127, 2013 WL 5281173, 2013 U.S. Dist. LEXIS 133633, Counsel Stack Legal Research, https://law.counselstack.com/opinion/minnis-v-board-of-supervisors-of-louisiana-state-university-agricultural-lamd-2013.