Dr. Leonard Chukwualuka Onyiah v. St. Cloud State University
684 F.3d 711
| 8th Cir. | 2012Background
- Onyiah, a black Nigerian-born professor, sued St. Cloud State University and MnSCU for wage discrimination based on race, national origin, and age under Title VII and the ADEA.
- Onyiah was hired in 1998 with an above-range initial salary; subsequent hires used a salary-range grid or algorithm, with raises tied to CBA provisions and negotiated adjustments.
- The dean and department chair set initial salaries; Onyiah’s salary history shows a progression from initial over-range offers in 1998–2001 to continued adjustments under MnSCU/IFO policy.
- MnSCU faculty salaries are governed by the IFO collective bargaining agreement; initial salaries are set by a dean with input from department leadership, and later changes may occur via MOA or recoding.
- Onyiah alleged tribal-affiliation discrimination but the district court and this court found lack of exhaustion and failure to plead or exhaust for tribal-based national-origin claims.
- The district court granted summary judgment for the University in 2011 on all remaining Title VII and ADEA claims; Onyiah’s expert on salaries was excluded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Title VII salary discrimination prima facie and pretext | Onyiah alleged race/national origin discrimination in pay based on comparators and policy. | University followed standard salary grids and Onyiah failed to show pretext. | Summary judgment affirmed; no pretext shown. |
| ADEA salary discrimination prima facie and pretext | Age discrimination led to lower pay compared to younger colleagues. | Pay disparity consistent with policy and non-discriminatory factors. | Summary judgment affirmed; no pretext shown. |
| tribal affiliation national-origin claim exhaustion | Tribal affiliation should support a national-origin claim. | Claim not exhausted and not raised in EEOC charge or amended complaint. | District court’s failure to address tribal claim affirmed; no consideration given. |
| Lilly Ledbetter Fair Pay Act impact | FPA altered burden or timeliness for pay discrimination claims. | FPA changes paycheck accrual, not burden of proof in Title VII/ADEA claims. | FPA not altering burden; district court's dismissal affirmed. |
| Exclusion of expert testimony on salary | Kalia could determine proper initial salary and underpayment amount. | Kalia not qualified and testimony speculative. | Exclusion affirmed; district court did not abuse discretion. |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (Supreme Court 1973) (establishes burden-shifting framework for discrimination claims)
- Torgerson v. City of Rochester, 643 F.3d 1031 (8th Cir. 2011) (material-fact burden shifting; similarly situated comparators must be analyzed)
- Heacker v. Safeco Ins. Co., 676 F.3d 724 (8th Cir. 2012) (de novo review of summary judgment; standard for review)
- Hatchett v. Health Care & Retirement Corp., 186 Fed. Appx. 543 (6th Cir. 2006) (unpublished; relevance to negotiation as a factor in pay decisions)
- Gibson v. American Greetings Corp., 670 F.3d 844 (8th Cir. 2012) (pretext requires evidence of nondiscriminatory reason being false or unworthy of credence)
- Rahlf v. Mo-Tech Corp., 642 F.3d 633 (8th Cir. 2011) (ADEA prima facie and pretext framework)
- Gross v. FBL Fin. Servs., Inc., 557 U.S. 167 (Supreme Court 2009) (but-for causation standard under ADEA claims)