Minnis v. Board of Supervisors of Louisiana State University & Agricultural & Mechanical College, 972 F. Supp. 2d 878

Background

Minnis, a black male, was LSU Women’s Tennis Head Coach from 1991 until his termination on June 30, 2012.
He alleges race-based pay disparities, discriminatory evaluations, false reprimands, and retaliation for opposing sex equity and Title IX concerns.
Minnis reports discovery that he was paid less than other SEC head coaches, contrary to representations by Segar, Alieva, and Nunez.
Administrators Segar, Alieva, and Nunez (and LSU) are named as defendants in claims under §1981, §1983, Title VII, Title IX, and state law.
He contends the administrators failed to provide reasons for termination, made adverse reference inquiries, and imposed unactioned negative evaluations.
The court considers motions to dismiss under Rule 12(b)(6) challenging several claims against LSU and the Administrator Defendants.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
§1981 official-capacity claims bar	Minnis asserts §1981 against LSU and Segar/Nunez/Alieva in official capacities.	Defendants contend §1981 cannot be asserted against state actors in official capacities; must proceed via §1983.	GRANTED; §1981 official-capacity claims dismissed.
Individual-capacity §1981/§1983 against administrators	Minnis pleads individual liability for §1981 and §1983 against Segar, Nunez, and Alieva.	Administrators are entitled to qualified immunity; claims fail if rights were not clearly established.	GRANTED; qualified immunity bars §1981/§1983 claims against Segar, Nunez, and Alieva in their individual capacities.
§1983 official-capacity claims	Minnis sues LSU and administrators in official capacities under §1983 for constitutional deprivations.	State actors in official capacities are not “persons” under §1983; Ex Parte Young limits apply but no violation shown.	GRANTED; §1983 official-capacity claims against LSU and administrators dismissed.
Title VII against individuals	Minnis asserts Title VII discrimination/retaliation by Administrator Defendants.	Title VII does not permit individual liability; only against employers (Louisiana State University).	GRANTED; Title VII claims against individual administrators dismissed.
Title IX against administrators; punitive damages	Minnis asserts Title IX violations by administrators; seeks punitive damages where applicable.	Title IX not liable against individuals; punitive damages not available in Title IX actions; LSU may proceed.	GRANTED as to administrators; punitive damages under Title IX dismissed; Title IX claims against LSU remain.

Key Cases Cited

Will v. Michigan Dept. of State Police, 491 U.S. 58 (1989) (states that §1983 provides remedies for deprivations of rights established elsewhere; not substantive rights itself)
Ex Parte Young, 209 U.S. 123 (1908) (exemption to Eleventh Amendment via ongoing unconstitutional enforcement; permits suits against state officials)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (requires plausible factual allegations to state a claim)
Twombly, 550 U.S. 544 (2007) (plausibility standard for pleading a claim)
Oden v. Oktibbeha County, Miss., 246 F.3d 458 (5th Cir. 2001) (§1981 claims cannot proceed independently against government actors in official capacity; must proceed via §1983)
Grant v. Lone Star Co., 21 F.3d 649 (5th Cir. 1994) (Title VII liability generally limited to employers, not individual supervisors)
Ackel v. Nat'l Commc’ns, Inc., 339 F.3d 376 (5th Cir. 2003) (individuals not liable under Title VII)
Foley v. Univ. of Houston Sys., 355 F.3d 333 (5th Cir. 2003) (no individual liability under Title VII)
Barrett v. Fitzgerald, 555 U.S. 246 (S. Ct. 2009) (Title IX private right of action recognized; individuals generally not target)