Tyler v. Trustees of Purdue University, 834 F. Supp. 2d 830

Tyler became Director of Organizational Effectiveness (OE) for Information Technology at Purdue ITaP around April 14, 2005, with OE tasked to support all seven ITaP units and to implement the Job Family System.
In January 2006, Tyler was assigned to manage three ITaP units (Communications, Informatics & Media Relations, Video/Multimedia) and received high performance ratings, while others were rated lower.
June 2006, Interim CIO McCartney reorganized ITaP, finding OE unnecessary and identifying five positions (including Tyler's) for elimination to refocus ITaP on core research computing.
On January 9, 2007, Purdue notified Tyler that her position would be eliminated and she would be laid off, with other support positions also eliminated; Coryell was retained/reshaped to absorb Tyler’s duties.
A grievance process reviewed the RIF, with a committee finding Tyler’s KSAs not equal to Coryell’s for the Executive Director, Administrative Services position, and upholding the elimination of Tyler’s OE role.
Tyler filed suit in November 2008 alleging Title VII gender discrimination, retaliation, and age discrimination, plus contract-based claims; Purdue moved for summary judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Title VII gender discrimination prima facie and pretext	Tyler claims she was discriminated against due to gender in the RIF.	RIF was based on core ITaP mission; Tyler’s duties absorbed by a male co-employee; reasons stated were legitimate.	Tyler fails to show pretext; no genuine issue of material fact; claim fails.
Retaliation under Title VII and EPA	Tyler was retaliated against for protected activity opposing pay disparities and complaining about a colleague’s promotion process.	Same legitimate ITaP reorganization justification; no pretext shown.	Retaliation claims fail; no pretext proven.
ADEA claim and Eleventh Amendment immunity	Tyler seeks age discrimination relief; claims should proceed notwithstanding immunity.	Purdue University is a state entity immune from suit; Ex parte Young not applicable to state entity.	ADEA claim barred by Eleventh Amendment immunity; no jurisdiction.
Supplemental state-law claims (breach of contract, promissory estoppel)	Tyler argues Purdue breached her employment contract and made promissory promises relevant to reinstatement.	Terms of Memorandum B-55 and appointment provided termination rights; no breach or promissory-estoppel remedy merited.	Court exercises supplemental jurisdiction; dismisses contract and promissory estoppel claims.

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. Supreme Court, 1973) (establishes burden-shifting framework for discrimination claims)
Bellaver v. Quanex Corp., 200 F.3d 485 (7th Cir. 2000) (mini-RIF framework; differentiation from traditional RIF)
Merillat v. Metal Spinners, Inc., 470 F.3d 685 (7th Cir. 2006) (mini-RIF analysis; duties absorbed by others supports inference of discrimination)
Michas v. Health Cost Controls of Ill., Inc., 209 F.3d 687 (7th Cir. 2000) (discusses mini-RIF and KSAs in discrimination context)
Petts v. Rockledge Furniture LLC, 534 F.3d 715 (7th Cir. 2008) (mini-RIF considered by Seventh Circuit; focus on duties absorption)
Krchnavy v. Limagrain Genetics Corp., 294 F.3d 871 (7th Cir. 2002) (special considerations for prima facie discrimination cases)
O’Regan v. Arbitration Forums, Inc., 246 F.3d 975 (7th Cir. 2001) (recognizes McDonnell Douglas framework applicability to sex/age claims)
Ritter v. Hill ’N Dale, 231 F.3d 1039 (7th Cir. 2000) (limits judicial review of business decisions; not a super-PHD review)
Ost v. W. Suburban Travelers Limousine, Inc., 88 F.3d 435 (7th Cir. 1996) (emphasizes non-intrusiveness of court in employment decisions)