Case Law Update: Minnis v. Board of Supervisors of Louisiana State University and Agricultural and Mechanical College

CASE LAW UPDATE

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Minnis v. Board of Supervisors of Louisiana State University and Agricultural and Mechanical College

2015 WL 3941846 (June 29, 2015)

Mr. Minnis, the former coach of the LSU women’s tennis team sued the University claiming Title VII and Title IX discrimination when the University failed to renew his contract in June of 2012. Minnis was hired in 1991 and was the first African-American coach of any sport in the school’s history. Minnis coached at the University for 21 years. Although Minnis received coaching awards, the women’s tennis team struggled during his 21 years, and only achieved a winning record on three occasions during the 21 year period. In the three years prior to his termination, the team had a losing season. Additionally, Minnis received performance evaluations during his tenure which were generally mixed. When Minnis was terminated, he was replaced by a white female at a higher salary.

In affirming the dismissal of the Plaintiff’s case, the Court noted that Minnis was a member of a protected class but that he was not able to rebut the University’s non-discriminatory reasons for his termination where he failed to meet established goals, he had a losing record and his team had morale issues. Further, the Court found that his reprimand because he was aware that a student had been drinking before a charity event and negative performance evaluations were not enough to establish a race-based hostile work environment claim. Finally, the Court held that Minnis failed to establish a Title XI retaliation case because both the men’s coach and Minnis complained about the off campus practice facility, thus disproving a case of gender inequality.

Patrick R. Sturdy is a partner in our Livonia office where he concentrates his practice on intellectual property, business law, education law, and employment and labor law. He may be reached at (734) 261-2400 or psturdy@cmda-law.com.