Ian Maitland v. University of Minnesota

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.

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

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