Isabelle Blasdel v. Northwestern Un
2012 U.S. App. LEXIS 14770
7th Cir.2012Background
- Blasdel, a female physiologist, was hired by Northwestern in 2003 as an associate professor with a four-year tenure clock.
- She later reoriented research from Parkinson’s to drug addiction, sought extensions, and faced criticism for publication and funding gaps.
- A departmental and ad hoc committee recommended against tenure; Northwestern’s dean and provost ultimately denied tenure.
- Blasdel argues the denial was tainted by sex discrimination despite the university’s lack of explicit prejudice evidence.
- The district court granted summary judgment for Northwestern on the tenure claim, and the Seventh Circuit affirmed.
- Evidence included comparisons with Bevan (male colleague) and Miller (male), and claims of family-related delays but no direct prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Blasdel denied tenure due to sex? | Blasdel argues gender bias influenced decision. | No proven bias; decision based on productivity and funding. | No reasonable inference of sex discrimination; summary judgment affirmed. |
| Did procedural errors in the internal appeal create a triable issue? | Appeal procedure flaw suggests discrimination. | Procedural irregularity insufficient to raise Title VII issue. | Procedural error not enough; no triable issue. |
| Can comparative evidence (Bevan vs. Blasdel) support discrimination claim? | Bevan’s favor over Blasdel shows bias. | Bevan and Blasdel had different records and contexts; not a protected-class tilt. | Not enough to prove discrimination. |
| Does absence of objective tenure criteria doom discrimination claim in academia? | Subjective tenure process invites discriminatory outcomes. | Subjectivity is inherent; absence of bias evidence defeats claim. | Academic tenure’s subjectivity does not establish Title VII violation here. |
Key Cases Cited
- University of Pennsylvania v. EEOC, 493 U.S. 182 (1990) (academic tenure processes fall under Title VII enforcement)
- Namenwirth v. Board of Regents of University of Wisconsin System, 769 F.2d 1235 (7th Cir. 1985) (tenure decisions rely on judgments about academic potential)
- Lieberman v. Gant, 630 F.2d 60 (2d Cir. 1980) (common actor presumption discussed)
- Grutter v. Bollinger, 539 U.S. 306 (2003) (academic freedom and institutional autonomy acknowledged)
- Sun v. Board of Trustees of University of Illinois, 473 F.3d 799 (7th Cir. 2007) (contextual factors in tenure discrimination analyzed)
- Petts v. Rockledge Furniture LLC, 534 F.3d 715 (7th Cir. 2008) (comparator evidence and discrimination claims examined)