Raj v. Louisiana State University
714 F.3d 322
| 5th Cir. | 2013Background
- Raj, a tenured LSU professor, alleges race, religion, national origin, age, and sex discrimination against LSU, LSU Health, and the LSU Board.
- He claims salary disparities, retaliation, loss of grants, lab closure, reassignment, and unfavorable conditions tied to grant funding.
- Eleventh Amendment sovereign immunity bars his ADEA, §1983, §1985, and state-law claims against the LSU Board as an arm of the state.
- District court dismissed LSU/LSU Health for lack of capacity and bar under Eleventh Amendment for ADEA and §1983/§1985, and dismissed remaining claims under Rule 12(b)(6).
- Raj appeals, arguing district court erred in subject-matter jurisdiction and in failing to allow amendments; the court affirms dismissal.
- Court accepts well-pled facts for Rule 12(b)(6) review and analyzes the sovereign-immunity barrier prior to evaluating pleading sufficiency.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Eleventh Amendment sovereign immunity bars Raj’s ADEA and §1983/§1985 claims. | Raj asserts federal jurisdiction over claims against state entities. | LSU Board is an arm of the state; immunity applies. | Yes; ADEA and §1983/§1985 claims barred by Eleventh Amendment sovereign immunity. |
| Whether Raj’s state-law claims are barred by sovereign immunity. | Raj sues the university entities for state-law claims. | State sovereign immunity extends to claims against state entities in federal court. | Yes; state-law claims barred by sovereign immunity under Pennhurst principles. |
| Whether Raj stated a plausible Title VII disparate-treatment claim or other constitutional claims under Rule 12(b)(6). | Raj alleged adverse actions and discrimination based on race/national origin. | Alleged actions not linked to protected status; no plausible claim. | Raj failed to state a Title VII disparate-treatment claim; no plausible hostile environment or constructive-discharge claim; district court’s dismissal affirmed. |
Key Cases Cited
- Richardson v. Southern Univ., 118 F.3d 450 (5th Cir. 1997) (arm-of-the-state analysis for sovereign immunity under Eleventh Amendment)
- Delahoussaye v. City of New Iberia, 937 F.2d 144 (5th Cir. 1991) (six-factor test for whether a state university is an arm of the state)
- Pennhurst State School & Hosp. v. Halderman, 465 U.S. 89 (1984) (sovereign immunity bars federal suits on state-law claims against state entities)
- Ex parte Young, 209 U.S. 123 (1908) (immunity exception for injunctions against state officials acting in federal law violations)
- Kanida v. Gulf Coast Medical Personnel LP, 363 F.3d 568 (5th Cir. 2004) (adverse-action inquiry in Title VII disparate-treatment cases)
- Swierkiewicz v. Sorema N.A., 534 U.S. 506 (2002) (pleading standard: no need for prima facie case at the pleading stage)
- Jurgens v. EEOC, 903 F.2d 386 (5th Cir. 1990) (pleading standards for discrimination claims)
- Richardson v. Univ. of Louisiana at Monroe, ? (?) (arguments cited for arm-of-state status of LSU Board)