A federal judge from the Middle District of Louisiana has granted Louisiana State University’s motion to dismiss in a case in which the school was sued by its former women’s tennis coach for racial discrimination.
In essence, the court found that LSU had legitimate reasons for firing Plaintiff Anthony Minnis — his failure to consistently win.
Minnis was hired by LSU in 1991. During his tenure as head coach, the LSU women’s tennis team achieved a winning record only four times overall, and on only three occasions in the SEC (1997, 2004, and 2008). His overall SEC won-loss record as head coach was 86-146. While head coach, Minnis’ teams competed in the NCAA tournament 15 out of 21 years. But in Minnis’ last 12 years, the team never advanced past the second round. In the year preceding Minnis’ termination, his team did not reach the NCAA tournament, and in the three years preceding the non-renewal of Minnis’ contract, the women’s tennis team had three consecutive losing seasons.
Minnis sued the school for racial discrimination in 2012 after the school fired him. Among other things, he claimed that similarly situated white coaches were paid more and judged less harshly.
Named in the lawsuit are LSU Athletic Director Joseph Alleva; Senior Associate AD Eddie Nunez, and Senior Women’s Administrator Miriam Segar.
In its motion to dismiss, LSU suggested that student-athletes had “complained that Minnis created unnecessary tension during matches rather than offering tactical advice. And that he yelled and would not accept their input and often threatened to revoke scholarships. They were also concerned that Minnis was unorganized, conducted team meetings that lasted several hours and did not provide them constructive feedback.”
The court first examined Minnis claim of a violation of Title VII, which prohibits discrimination by employers “against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s race, color, religion, sex, or national origin.” 42 U.S.C. § 2000e-2(a). The court turned to the burden-shifting framework established by the United States Supreme Court in McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802, 93 S. Ct. 1817, 36 L. Ed. 2d 668 (1973) for guidance.
“To overcome a motion for summary judgment on his remaining discrimination claims, Minnis must first establish, by a preponderance of the evidence, a prima facie case of discrimination. McDonnell Douglas, 411 U.S. at 801-803. A prima facie case is established once the plaintiff has proven that he or she: (1) is a member of a protected class; (2) was qualified for his position; (3) was subjected to an adverse employment action; and (4) was replaced by someone outside the protected class; or in the case of disparate treatment, show that others similarly situated were treated more favorably. Id.”
Once a prima facie case is established, “the defendant must rebut by articulating a legitimate, nondiscriminatory reason for its actions. McDonnell Douglas, 411 U.S. at 802”
If the defendant satisfies that burden, the plaintiff “must then create a genuine issue of material fact that either: (1) the defendant’s reason is not true, but instead is a pretext for discrimination (pretext alternative); or (2) regardless of the nondiscriminatory reason, the plaintiff’s race was also a motivating factor (mixed-motives alternative). Alvarado v. Tex. Rangers, 492 F.3d 605, 611 (5th Cir. 2007)”
The court reasoned that Minnis’s Title VII falls short. While he satisfied the first three elements mentioned above, he failed in demonstrating that the other coaches were similarly situated to him. Specifically, he “failed to point to evidence detailing the job responsibilities, duties, and expectations or competitive success of the head coaches of other LSU sports. Rather, he merely points to the differences in salaries. … Thus, the court has not been provided with sufficient evidence to evaluate whether the head coaches of other sports are ‘similarly situated’ to Minnis.
“ … Moreover, though Minnis asserts that his termination is attributable to race discrimination, he has failed to point to any cases where a similarly-situated party, i.e., a coach with a losing record, succeeded in showing that his termination was based on his race.”
The court elaborated on Minnis’ mediocre record as a “legitimate” reason for LSU to terminate him. “In a profession created around competitive success, Minnis had a lackluster record,” wrote the court.
“Simply put, Minnis has failed to point to sufficient evidence from which a jury could conclude that the alleged harassment complained of was severe or pervasive enough to affect a term, condition, or privilege of his employment,” the court added.
Minnis’ attorney, Jill Craft, said her client will appeal the ruling to the 5th U.S. Circuit Court of Appeals in New Orleans.
“We’re obviously disappointed, but we have every intention to appeal it,” she told the media. “He’s still confident in his case and confident that justice will eventually be served.”
Anthony Minnis v. Board of Supervisors Of Louisiana State University and Agricultural and Mechanical College et al.; M.D. La.; Civil Action No.: 13-00005-BAJ-RLB, 2014 U.S. Dist. LEXIS 149514; 10/21/14
Attorneys of Record: (for plaintiff) Jill L. Craft, LEAD ATTORNEY, Baton Rouge, LA, USA; Amanda E. Love, Houston, TX, USA; Crystal LaFleur, Jil L. Craft, Attorney at Law, LLC, Baton Rouge, LA, USA. (for defendant) Robert W. Barton, LEAD ATTORNEY, Deborah E. Lamb, Vicki M. Crochet, Taylor, Porter, Brooks & Phillips, Baton Rouge, LA, USA.
