Ray Haynes v. Indiana University, 902 F.3d 724

Haynes, a Black assistant professor at Indiana University hired on a six-year probationary contract, was denied tenure after multi-tier faculty review (department, school, university committees). 27 faculty members voted; majority found his research not "excellent" and teaching "unsatisfactory."
Haynes submitted a dossier with letters from six external reviewers; most were positive but one reviewer, Patricia Hardré, criticized research rigor and referenced his race in a mixed context.
Haynes pursued internal appeals, filed an EEOC complaint, then sued under 42 U.S.C. § 1981 and Title VII seeking injunctive relief and damages; the district court granted summary judgment to the University.
The district court excluded three expert submissions (Perna declaration/report and Greenwald report) under Rule 702/Daubert and denied late supplementation of expert reports.
The Seventh Circuit affirmed: Title VII claim dismissed as time-barred (untimely EEOC filing), damages barred by sovereign immunity, and the remaining § 1981 injunctive claim failed on the merits for lack of evidence of intentional race-based discrimination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness of Title VII claim	Haynes argued equitable tolling should excuse late EEOC filing	University argued EEOC complaint filed after 300-day deadline	Title VII claim barred; Haynes knew of claim earlier and waited too long
Damages under § 1981 against state actors	Haynes sought monetary relief from University and administrators	University invoked sovereign immunity for state and state-actor defendants	Damages barred by sovereign immunity; only injunctive relief against officials in official capacity survives
Admissibility/supplementation of expert reports (Rule 702/Daubert)	Perna and Greenwald would show improper process and implicit bias; sought to supplement late	University moved to strike; court cited lack of specialized reliable methodology and lateness	Exclusion affirmed: Perna lacked discipline-specific expertise; Greenwald irrelevant to § 1981 (requires intentional discrimination); supplementation properly denied
Merits: intentional discrimination in tenure decision	Haynes pointed to allegedly irregular review, positive prior evaluations, lack of Black male tenured hires, and Hardré’s comments	University relied on detailed multi-layer negative evaluations and absence of evidence of race-motivated decision	Judgment affirmed: no admissible evidence that race caused tenure denial; academic judgments not second-guessed

Daubert v. Merrell Dow Pharm., 509 U.S. 579 (expert testimony admissibility)
Ortiz v. Werner Enters., Inc., 834 F.3d 760 (causation standard for discriminatory discharge/adverse action)
Sun v. Bd. of Trs. of Univ. of Ill., 473 F.3d 799 (courts defer on academic tenure judgments)
Hentosh v. Herman M. Finch Univ. of Health Scis./The Chi. Med. Sch., 167 F.3d 1170 (equitable tolling standards for EEOC filing)
Omosegbon v. Wells, 335 F.3d 668 (sovereign immunity bars damages for employment-contract injuries against state officials)
St. Mary’s Honor Ctr. v. Hicks, 509 U.S. 502 (plaintiff must prove discrimination was the real reason for adverse action)
Manley v. Law, 889 F.3d 885 (standard of review for summary judgment in Seventh Circuit)