Constance A. Onyiah v. St. Cloud State University
5 F.4th 926
| 8th Cir. | 2021Background
- Dr. Leonard Onyiah was a tenured statistics professor at St. Cloud State University who alleged race and national-origin discrimination and retaliation arising from faculty scheduling, resources, and program participation decisions between 2013–2018.
- Onyiah alleged retaliation for (a) a prior federal lawsuit (ended 2013) and (b) an internal discrimination complaint filed in October 2013.
- He sued the Minnesota State Colleges and Universities system, the University, and five University employees, asserting § 1981 and § 1983 claims for discrimination and retaliation and seeking damages and injunctive relief.
- The magistrate judge and district court dismissed Onyiah’s freestanding § 1981 claims (12(b)(6)), concluding § 1981 claims against state actors must be pursued under § 1983; seven § 1981-based claims remained under § 1983 against individual defendants.
- The district court granted summary judgment (Fed. R. Civ. P. 56) for the individual defendants on the remaining retaliation and discrimination claims under the McDonnell Douglas burden-shifting framework, concluding Onyiah failed to show causation and, alternatively, pretext.
- Onyiah died during the appeal and his wife was substituted; his request for injunctive relief was held moot.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether freestanding § 1981 retaliation claims may be asserted against state actors (i.e., directly under § 1981 rather than via § 1983) | § 1981 as amended by the Civil Rights Act of 1991 creates a direct cause of action against state actors, overruling Jett | Federal precedent requires § 1981 claims against state actors to be brought through § 1983; freestanding § 1981 claims against states are not allowed | Court: Eighth Circuit precedent controls—freestanding § 1981 claims against state actors are barred; such claims must be pursued under § 1983 (dismissal affirmed) |
| Whether Onyiah established a prima facie retaliation claim (causation) under McDonnell Douglas (timing and causal link between protected activity and adverse acts) | Protected activity (prior suit and 2013 complaint) and subsequent adverse employment actions in 2016–2018 support an inference of retaliation | The temporal gap (years) is too long absent other direct evidence; no direct evidence of retaliatory motive | Court: No genuine dispute on causation; temporal gap insufficient to create an inference of causation—summary judgment for defendants affirmed |
| Whether Onyiah showed defendants' legitimate, non-retaliatory reasons were pretextual | Evidence and inferences from the record establish pretext and permit trial | Defendants proffered legitimate, non-retaliatory reasons and plaintiff produced no probative evidence of pretext | Court: Plaintiff failed to prove pretext as required; summary judgment proper (alternative ground) |
| Mootness of injunctive relief given Onyiah’s death | Requested injunctive relief remains relevant | Injunctive relief against defendants is moot on plaintiff’s death | Court: Request for injunctive relief is moot; claim dismissed |
Key Cases Cited
- Artis v. Francis Howell N. Band Booster Ass’n, Inc., 161 F.3d 1178 (8th Cir.) (federal action to enforce § 1981 rights against state actors must be brought pursuant to § 1983)
- Jett v. Dallas Indep. Sch. Dist., 491 U.S. 701 (1989) (§ 1983 is the exclusive federal remedy for violations of § 1981 by state governmental units)
- Flowers v. City of Minneapolis, 558 F.3d 794 (8th Cir. 2009) (reaffirms that § 1981 claims against municipalities/state actors proceed via § 1983)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden-shifting framework for discrimination/retaliation cases)
- CBOCS West, Inc. v. Humphries, 553 U.S. 442 (2008) (§ 1981 encompasses retaliation claims)
- Williams v. UPS, 963 F.3d 803 (8th Cir. 2020) (discusses prima facie elements for § 1981 retaliation and the temporal proximity/causation standard)