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Keywords

plaintiffdefendantdiscoverymotionsummary judgmentdiscriminationmotion for summary judgment
plaintiffdefendantdiscoverymotionsummary judgmentdiscrimination

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Pyo v. Stockton State College, 603 F.Supp. 1278, 37 Fair Empl.Prac.Cas. (BNA) 493, 23 Ed. Law Rep. 900

Facts

The plaintiff, an assistant professor in the Department of Art at Stockton State College, was denied tenure in December 1981, leading to her termination. She claimed that this decision was influenced by sex and race discrimination, as she is of Asian descent. The college's tenure decision process involved multiple evaluations, including peer reviews and recommendations from faculty and administration, with mixed results regarding her qualifications. Ultimately, the Faculty Review Committee recommended tenure, but the dean and vice president recommended against it, leading to the president's decision to deny tenure.

The tenure decision process is a multi-step process at Stockton State College. During their fifth consecutive year of employment with the college, faculty members are evaluated to determine if they should be reappointed with tenure. If tenure is denied, employment is generally terminated.

Issue

Whether the court should strike the plaintiff's request for a judicial award of tenure as a possible remedy in her employment discrimination case.

The defendant is moving for partial summary judgment. The motion is a very limited one. The defendant merely seeks an order striking a judicial award of tenure as a possible remedy in this case.

Rule

Judicial awards of tenure may be appropriate under Title VII if they are necessary to make a plaintiff whole for discrimination suffered, but courts generally defer to university evaluations unless discrimination is evident.

Since the central purpose of Title VII is to make persons whole for the harm suffered on account of unlawful employment discrimination, Albemarle Paper Co. v. Moody, 422 U.S. 405, 418, 95 S.Ct. 2362, 2372, 45 L.Ed.2d 280 (1975); a judicial award of tenure is, under appropriate circumstances—where an award would make one whole, rather than act as a windfall—certainly a possibility.

Analysis

The court analyzed the tenure decision process and the mixed evaluations of the plaintiff's qualifications. It noted that while the Faculty Review Committee had recommended tenure, the subsequent recommendations against tenure from the dean and vice president raised questions about the sincerity of the evaluations. The court acknowledged that if discrimination influenced the decision-making process, it could justify a judicial award of tenure, but further discovery was needed to clarify the nature of any discrimination.

The court is thus faced with the dual obligation of faithfully upholding the goal of Title VII of making the plaintiff whole, while also exercising proper restraint and deference with regard to university officials.

Conclusion

The court denied the defendant's motion for partial summary judgment, allowing the possibility of a judicial award of tenure to remain open pending further discovery on the discrimination claims.

The court, of course, expresses no opinion regarding the merits of plaintiff's case. Further discovery on discrimination, as relevant to the relief sought, is clearly appropriate, however.

Who won?

The plaintiff prevailed in the sense that the court denied the defendant's motion for summary judgment, allowing her claims to proceed and the possibility of a judicial award of tenure to remain.

The court denied the defendant's motion for partial summary judgment, ruling that substantial issues of material fact existed as to whether tenure should be judicially awarded, precluding summary judgment.

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