Date: 08-15-2001

Case Style: Ian Maitland v. University of Minnesota

Case Number: 00-2192

Judge: Bowman

Court: United States Court of Appeals for the Eighth Circuit

Plaintiff's Attorney: Unknown

Defendant's Attorney: Unknown

Description: Ian Maitland, a male professor at the University of Minnesota, sued the University and other officials in 1993 under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e to 2000e-17 (1994 & Supp. IV 1998), claiming that the Rajender II salary increases for female faculty members had created a discriminatory pay structure tilted against himself and other male faculty members. The District Court granted summary judgment to the University after concluding that Maitland's claims were barred by the Civil Rights Act of 1991 and under principles of estoppel. Maitland v. Univ. of Minn., Civ. No. 3-93-91 (D. Minn. July 12, 1993). We reversed the District Court on both grounds. Maitland v. Univ. of Minn., 43 F.3d 357 (8th Cir. 1994) (Maitland I).

On remand, Maitland asserted an additional claim for damages under section 102(a) of the Civil Rights Act of 1991, 42 U.S.C. § 1981a (1994), and reasserted a 42 U.S.C. § 1983 claim (which had previously been dismissed) that alleged the University had violated his equal protection rights. In 1996, the District Court granted summary judgment to the University, finding that Maitland was ineligible to recover under his section 102(a) damages claim, that the individual defendants were entitled to qualified immunity, and that the University and the individual defendants were entitled to judgment as a matter of law on the remaining claims. Maitland v. Univ. of Minn., Civ. No. 4-93-25 (D. Minn. Dec. 6, 1996). Again, we reversed. See Maitland v. Univ. of Minn., 155 F.3d 1013, 1019 (8th Cir. 1998) (Maitland II).2

On remand, the University filed a motion to dismiss or, in the alternative, for partial summary judgment on four different grounds. First, the individual defendants argued that they had absolute legislative immunity when they approved the Rajender II settlement, thereby barring Maitland's § 1983 claim against them. Second, the defendants argued that Congress exceeded its constitutional authority under Section 5 of the Fourteenth Amendment when it abrogated the University's Eleventh Amendment immunity with respect to Title VII sex-discrimination claims brought by men. Third, the defendants argued that recent changes to Maitland's salary have rendered his back-pay and injunctive-relief claims moot. Finally, the defendants argued that Maitland failed to join indispensable parties, i.e., members of the Rajender II class from whom the defendants contended Maitland was seeking divestiture relief. The District Court 3 denied the motion on all four grounds. Maitland v. Univ. of Minn., Civ. No. 4-93-25 (D. Minn. Mar. 29, 2000). The defendants bring this interlocutory appeal challenging the District Court's rulings on the legislative-immunity and Eleventh Amendment issues.

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Click the case caption above for the full text of the Court's opinion.

Outcome: The rulings of the District Court challenged in this interlocutory appeal are affirmed and the case is remanded for further proceedings.

Plaintiff's Experts: Unknown

Defendant's Experts: Unknown

Comments: None