Summary
The First Circuit affirmed a district court judgment finding that sex discrimination impeded Dr. Christine Sweeney’s second effort to obtain promotion at Keene State College. The court upheld the backdated promotion and related Title VII relief, while leaving undisturbed findings rejecting her salary-discrimination, Equal Pay Act, Section 1983, Fourteenth Amendment, and Title IX claims. The court also affirmed the award of attorneys’ fees and costs.
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Practice areas
Questions Presented
- Whether the evidence was sufficient to support the finding that sex discrimination impeded Sweeney's second promotion effort in violation of Title VII.
- Whether a Title VII disparate-treatment plaintiff may prove discriminatory motive through circumstantial and statistical evidence rather than direct evidence.
- Whether the district court clearly erred in rejecting Sweeney's claim that sex discrimination caused her lower salary.
- Whether the district court properly awarded attorneys' fees, costs, and expenses after Sweeney prevailed in part.
- Whether the court should decide Sweeney's Equal Pay Act, Title IX, § 1983, and Fourteenth Amendment claims despite the Title VII judgment.
Holdings
- A Title VII plaintiff alleging disparate treatment may establish discriminatory motive through inferential, circumstantial, and statistical evidence; direct evidence of discriminatory intent is not required.
- The district court did not clearly err in finding that sex discrimination impeded Sweeney's second effort to obtain promotion to full professor.
- The district court's finding that Sweeney failed to prove that sex discrimination caused her individual salary disparity was not clearly erroneous.
- The district court properly awarded Sweeney attorneys' fees, costs, and expenses, including a reasonable fee reduced by 20 percent, despite her partial success.
Key quotations
“Nevertheless, we caution against permitting judicial deference to result in judicial abdication of a responsibility entrusted to the courts by Congress.” (176)
“It is clear, then, that a plaintiff may rely upon inferential proof of discriminatory motive in a disparate treatment case.” (177)
“The judgment is AFFIRMED.” (180)
Factual background
Christine Sweeney had been an associate professor of education at Keene State College since 1969 and was granted tenure in 1972. She sought promotion to full professor during the 1972-73 and 1974-75 academic years, but all-male faculty evaluation committees recommended against promotion and the dean concurred. She presented evidence of substantial sex disparities in faculty ranks and promotion, evidence concerning her own treatment, and evidence that Keene's affirmative-action program was ineffective. She was promoted during her third attempt in 1975-76, effective July 1, 1976.
Procedural history
Sweeney, a Keene State College faculty member, sued the college and associated officials alleging sex discrimination in promotion and compensation under Title VII, the Equal Pay Act, Title IX, 42 U.S.C. § 1983, and the Fourteenth Amendment. After a four-day trial, the District of New Hampshire found a pattern of sex discrimination in hiring, promotion, and salaries, but awarded relief only on the Title VII promotion claim and awarded attorneys' fees and costs. The defendants challenged the sufficiency of the evidence and discriminatory-motive finding, while Sweeney challenged adverse findings concerning salary discrimination and other claims. The First Circuit affirmed.