Fields v. Stephen F. Austin State University, 611 F. App'x 830

Plaintiffs Joann Fields and Rose Trotty are African-American shuttle bus drivers in Stephen F. Austin State University’s Physical Plant Department (PPD).
Trotty worked for the university since 1990 and Fields since 2006; Coker is the PPD Transportation and Special Services manager who supervises them.
They allege they are paid less than certain comparators performing substantially similar work and claim Coker created a hostile work environment based on race and sex.
Plaintiffs asserted wage-discrimination claims under Title VII and the Equal Pay Act, and Coker was sued individually under 42 U.S.C. § 1983 for equal-protection claims.
The district court granted summary judgment to the university and Coker on all claims; plaintiffs appeal the decision.
The court affirms the district court’s grant of summary judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Fields and Trotty show substantial similarity to comparators for wage claims	Fields/Trotty claim duties are substantially similar to comparators and pay difference violates Title VII/EP Act.	Comparators’ duties differ materially; plaintiffs fail to show nearly identical work.	No; no substantial similarity to comparators.
Whether the wage claims survive under Title VII and the Equal Pay Act	Disparities reflect race/sex-based pay inequities under both statutes.	Lack of substantial similarity defeats prima facie wage claims; no EP Act violation shown.	Claims fail; grant of summary judgment affirmed.
Whether Coker violated the Equal Protection Clause through hostile work environment	Coker harassed plaintiffs based on race/sex and assigned custodial duties selectively.	Harassment not sufficiently severe or pervasive; no link shown to race/sex.	No constitutional violation; qualified-immunity analysis not reached.

Taylor v. United Parcel Serv., Inc., 554 F.3d 510 (5th Cir. 2008) (nearly identical requirement for Title VII wage claims)
Chance v. Rice Univ., 984 F.2d 151 (5th Cir. 1993) (equal pay analysis requires equal skill/effort/responsibility)
Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment standard; burden to show essential elements)
Morgan v. Swanson, 659 F.3d 359 (5th Cir. 2011) (defining qualified immunity standard)
Ashcroft v. al-Kidd, 131 S. Ct. 2074 (2011) (clarifying clearly established rights for qualified immunity)
Ramsey v. Henderson, 286 F.3d 264 (5th Cir. 2002) (harassment must affect a condition of employment)
Lauderdale v. Texas Dep’t of Criminal Justice, Institutional Div., 512 F.3d 157 (5th Cir. 2007) (scope of hostile-work-environment claims under equal protection)
Berquist v. Washington Mut. Bank, 500 F.3d 344 (5th Cir. 2007) (standard of review for summary judgment)