Mohan Pauliah v. University of Mississippi Medical Center, et al.
3:23-cv-03113
S.D. Miss.Jun 16, 2025Background
- Plaintiff Dr. Mohan Pauliah, a former tenure-track Assistant Professor at the University of Mississippi Medical Center (UMMC), alleges breach of contract, constitutional violations, and employment discrimination after his termination.
- Dr. Pauliah's operative pleading (Second Amended Complaint) clarifies claims under several federal statutes, including the Age Discrimination in Employment Act (ADEA).
- Defendants—Institutions of Higher Learning (IHL) and its Board Members—moved for judgment on the pleadings, seeking dismissal for both procedural and substantive reasons.
- Key dispute: Whether Dr. Pauliah may pursue the remedy of reinstatement under the ADEA against state entity officials in their official capacities.
- Prior court order allowed amendment to add claims against individual Board Members (in their official capacities), but required the claim to be sufficiently articulated.
- UMMC and IHL have previously asserted that employment contracts of tenure-track professors require the Board's approval.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Monetary damages under ADEA vs. State entity | Did not pursue damages against the State, amended accordingly | State immune from such relief under Eleventh Amendment | Court agrees with state immunity |
| Prospective relief (reinstatement) under ADEA vs. officials | Sought reinstatement from officials in official capacity | Not properly pled; officials not needed for relief | Claim adequately pled for this stage |
| Adequacy of amended complaint's claim for reinstatement | Complaint fairly conformed to court's order | Clarification in complaint was improper post-order | Motion to dismiss denied |
| Necessity of individual Board Members for relief | Board has final approval over employment contracts | Board Members not necessary for reinstatement | Better resolved with further evidence; not dismissed |
Key Cases Cited
- Papin v. Univ. of Miss. Med. Ctr., 673 F. Supp. 3d 829 (S.D. Miss. 2023) (Board approval required for employment contracts at UMMC)
- Canon v. Bd. of Trs. of State Insts. of Higher Learning of Miss., 133 F. Supp. 3d 865 (S.D. Miss. 2015) (Employment contract is with IHL, supporting plaintiff's argument for naming the Board members)