Rosneck, Karen v. Evers, Tony

CourtDistrict Court, W.D. Wisconsin
DecidedSeptember 29, 2020
Docket3:19-cv-00702
StatusUnknown

This text of Rosneck, Karen v. Evers, Tony (Rosneck, Karen v. Evers, Tony) is published on Counsel Stack Legal Research, covering District Court, W.D. Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rosneck, Karen v. Evers, Tony, (W.D. Wis. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN

KAREN ROSNECK,

Plaintiff, v. OPINION and ORDER

TONY EVERS, REBECCA BLANK, 19-cv-702-jdp ANDREW PETERSON, RAY CROSS, and JOEL BRENNAN,

Defendants.

Pro se plaintiff Karen Rosneck, an advanced library service assistant (LSA) at the University of Wisconsin-Madison, alleges that university staff members have discriminated against her on the basis of her age and sex over the past 25 years by failing to properly classify her as a professional librarian or provide her with career advancement opportunities. Rosneck also alleges that her constitutional right to due process was violated by university staff and state and federal administrative agencies and courts in handling her complaints. She brings claims under the Age Discrimination in Employment Act (ADEA), a sex discrimination claim under 42 U.S.C. § 1981, and procedural due process and equal protection claims under 42 U.S.C. § 1983. Rosneck names as defendants high-ranking state government and university officials: Tony Evers, the Wisconsin governor; Rebecca Blank, chancellor of the University of Wisconsin-Madison; Andrew Peterson, president of the University of Wisconsin System Board of Regents; Ray Cross, (now former) president of the University of Wisconsin System; and Joel Brennan, secretary of the Wisconsin Department of Administration. Defendants have filed a motion to dismiss the case under Federal Rule of Civil Procedure 12(b)(6) for Rosneck’s failure to state a claim upon which relief can be granted. Dkt. 5. I will grant this motion in part and dismiss most of Rosneck’s claims. But I will give Rosneck a chance to submit an amended complaint fixing the problems with her claims regarding age discrimination in hiring for temporary librarian positions.

ALLEGATIONS OF FACT In her complaint, Rosneck alleges the following. Rosneck works in UW-Madison’s General Library System (GLS). Rosneck successfully appealed the reclassification of her paraprofessional advanced LSA-4 position to a lower title at a Wisconsin Employment Relations Commission (WERC) hearing in 1995. After this hearing, University of Wisconsin officials repeatedly denied her promotion to a professional- classified librarian position. The state Department of Administration issued an “anonymous directive” that prohibited the use of the classified librarian title in the UW System even though

that job title appears to remain available to employees under other legal agreements related to library staffing. Rosneck says that was meant to retaliate against her and to discriminate against her and her peers, women over the age of 40. In 1997, GLS introduced an intern program that limited the assignment of temporary professional academic librarian positions to individuals who graduated from a library science master’s degree program within the past year. The implementation of this program excluded Rosneck from consideration for these positions. In 1995 and 2001, GLS officials also did not interview Rosneck for Slavic cataloger and Slavic librarian positions despite her Slavic language

expertise and her qualification for the roles. The GLS instead hired younger men. Since at least 2002, Rosneck repeatedly filed sex and age discrimination claims in various Wisconsin state courts and agencies and argued that Wisconsin statutes classify her position as professional and entitle her to “career advancement in a classified service structure.” Dkt. 1, ¶¶ 8, 20–38. These courts and agencies have concluded that the university properly

acted in its discretion in choosing the “best fit” for the positions and not promoting Rosneck. Rosneck lists various instances of the adjudicators’ failure to follow the proper standards and abide by statutory requirements. She also alleges that a clerk at the Court of Appeals for the Seventh Circuit “sabotaged” her petition by “trashing” it or returning it to her. Id., ¶¶ 22–23.

ANALYSIS A motion to dismiss under Rule 12(b)(6) weighs the legal sufficiency of a complaint rather than its truthfulness: I must accept all well-pleaded facts in the complaint as true and then examine whether those allegations state plausible claims for relief. Firestone Fin. Corp. v.

Meyer, 796 F.3d 822, 826 (7th Cir. 2015). I am not required to agree with legal conclusions or conclusory allegations that simply recite the elements of a claim. Id. at 826–27. Defendants raise a host of problems with Rosneck’s allegations. Not all of the flaws are particularly serious; for instance, they point out that § 1981 is not the proper statute for bringing a sex discrimination claim. But pro se plaintiffs are generally not required to plead legal theories in their complaints. Small v. Chao, 398 F.3d 894, 898 (7th Cir. 2005). Rosneck already brings a constitutional sex discrimination claim under § 1983 and she could also bring claims under Title VII of the Civil Rights Act of 1964. So I wouldn’t dismiss the complaint for

this reason. But there are other more significant problems that doom most of her asserted claims. The only defendants that she names in her complaint are high-ranking university and state officials, none of whom appear to have any responsibility for any of the decisions that Rosneck says are harming her. Under § 1983, Rosneck can sue individuals who violated her

constitutional rights. But the statute does not establish a system of vicarious responsibility: liability depends on each defendant’s personal knowledge and actions. Burks v. Raemisch, 555 F.3d 592, 593–94 (7th Cir. 2009). Rosneck alleges that she copied some of the defendants in emails describing her claims to the Court of Appeals for the Seventh Circuit. It is unlikely that Rosneck’s emails to some of the highest-ranking officials in the state made them aware of her situation, and even if defendants did know of these circumstances, they wouldn’t be directly responsible for addressing the problem. The governor, UW chancellor, and other defendants generally appoint

others to handle these concerns. “Bureaucracies divide tasks” and no one can insist that “one employee do another’s job.” Id. at 595. So Rosneck fails to state a constitutional claim against any of the defendants in their individual capacities. These individuals are also not proper defendants for Rosneck’s damages claims under Title VII. Rosneck has to name her employer, and under state statute that is the UW System Board of Regents. See Garner v. State, 2011 WI App 1, ¶ 2, 330 Wis. 2d 833, 794 N.W.2d 927. And Rosneck cannot bring damages claims at all under the ADEA, because those claims are barred by sovereign immunity. Kimel v. Fla. Bd. of Regents, 528 U.S. 62, 73 (2000); Gore v. Ind.

Univ., 416 F.3d 590, 591–92 (7th Cir. 2005). So at the moment, she has not properly stated claims for damages under any of her proposed legal theories. Most of what she alleges are discrete actions that happened in the distant past, at least eight years and as much as 25 years prior to the filing of this complaint.

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Related

Ex Parte Young
209 U.S. 123 (Supreme Court, 1908)
Kimel v. Florida Board of Regents
528 U.S. 62 (Supreme Court, 2000)
Palka v. Shelton
623 F.3d 447 (Seventh Circuit, 2010)
John S. Gore v. Indiana University
416 F.3d 590 (Seventh Circuit, 2005)
Burks v. Raemisch
555 F.3d 592 (Seventh Circuit, 2009)
Rosneck v. Wis. Emp't Relations Comm'n
2018 WI App 71 (Court of Appeals of Wisconsin, 2018)
Firestone Financial Corp. v. Meyer
796 F.3d 822 (Seventh Circuit, 2015)

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Bluebook (online)
Rosneck, Karen v. Evers, Tony, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rosneck-karen-v-evers-tony-wiwd-2020.