Egerdahl v. Hibbing Community College, No. 95-1700
Court | United States Courts of Appeals. United States Court of Appeals (8th Circuit) |
Writing for the Court | Before RICHARD S. ARNOLD; RICHARD S. ARNOLD |
Citation | 72 F.3d 615 |
Docket Number | No. 95-1700 |
Decision Date | 18 December 1995 |
Parties | Jane Marie EGERDAHL, Appellant, v. HIBBING COMMUNITY COLLEGE; Minnesota Community College System; State of Minnesota; Myron Schmidt; Anthony Kuznik; and Jerry Krause, Appellees. |
Page 615
v.
HIBBING COMMUNITY COLLEGE; Minnesota Community College
System; State of Minnesota; Myron Schmidt;
Anthony Kuznik; and Jerry Krause, Appellees.
Eighth Circuit.
Decided Dec. 18, 1995.
Page 616
William James Mavity, Minneapolis, Minnesota, argued (Verdell F. Borth, Minneapolis, Minnesota, on the brief), for appellant.
Sharon Ann Lewis, St. Paul, Minnesota, argued (Hubert H. Humphrey, III, Attorney General, on the brief), for appellees State of MN, MN Community College and Hibbing Community College.
John Lawrence Kirwin, St. Paul, Minnesota, argued (Hubert H. Humphrey, III, Attorney General, and Steven J. Lokensgard, on the brief, for appellees Kuznik and Schmidt; David C. McDonald, on the brief, for Krause), for appellees.
Before RICHARD S. ARNOLD, Chief Judge, WHITE, * Associate Justice, and LOKEN, Circuit Judge.
Page 617
RICHARD S. ARNOLD, Chief Judge.
Jane Marie Egerdahl claims that the State of Minnesota, the Minnesota Community College System, Hibbing Community College ("Hibbing"), and three Hibbing employees discriminated against her on the basis of race and gender and, therefore, violated Title IX of the Education Amendments of 1972, 20 U.S.C. Sec. 1681 ("Title IX"), 42 U.S.C. Sec. 1981, 42 U.S.C. Sec. 1983, Title VI of the Civil Rights Act of 1964, 42 U.S.C. Sec. 2000d ("Title VI"), and the Equal Protection Clause of the Fourteenth Amendment. The District Court dismissed Egerdahl's suit. We reverse the District Court's dismissal of Egerdahl's Title IX and Title VI claims, but affirm its decision to dismiss her Sec. 1981, Sec. 1983, and equal-protection claims.
I.
During the fall of 1992, Jane Marie Egerdahl, who is part Native American, enrolled in a chemistry class at Hibbing Community College, a state-run school that receives federal funds. Egerdahl claims that Jerry Krause, a chemistry instructor at Hibbing, engaged in a pattern of discriminatory treatment based on Egerdahl's race and gender. According to Egerdahl, she reported Krause's conduct to Hibbing's Dean, Myron Schmidt, and its President, Anthony Kuznik, but the discrimination continued throughout the fall semester.
On October 1, 1993, Egerdahl filed charges with the Minnesota Department of Human Rights, claiming that the defendants had violated the Minnesota Human Rights Act ("MHRA"), Minn.Stat. Sec. 363.03. Egerdahl then withdrew her charge with the Department of Human Rights and, on June 7, 1994, filed this complaint in federal court, alleging violations of Title IX, Sec. 1981, Sec. 1983, the Equal Protection Clause, the MHRA, and state tort law. She later amended her complaint to drop her state-law claims and to add a claim under Title VI.
The District Court dismissed Egerdahl's suit. It held that Egerdahl's Title VI and Title IX claims were governed by the MHRA's one-year statute of limitations, Minn.Stat. Sec. 363.06, subd. 3, and that this limitations period had run before Egerdahl filed suit in federal court. The District Court also held that the Eleventh Amendment barred Egerdahl's Sec. 1981, Sec. 1983, and equal-protection claims.
II.
Egerdahl argues that the District Court erred by holding that the MHRA's one-year statute of limitations governs Title VI and Title IX claims. She asserts that the appropriate statute of limitations is the six-year limitations period of Minnesota's personal-injury statute, Minn.Stat. Sec. 541.05, subd. 1(5). We agree.
When, as in the case of Title VI and Title IX, a federal statute does not contain a limitations period, courts must select "the most appropriate or analogous state statute of limitations." Goodman v. Lukens Steel Company, 482 U.S. 656, 660, 107 S.Ct. 2617, 2620, 96 L.Ed.2d 572 (1987). The District Court relied on its decision in Deli v. University of Minnesota, 863 F.Supp. 958 (D.Minn.1994), which held that the MHRA's limitations period should apply to Title IX claims because "[b]oth the MHRA and Title IX proscribe discrimination in educational institutions on the basis of gender and essentially seek to make whole the victims of such discrimination." Id. at 962. 1 In addition, the District Court extended the reasoning that it employed in Deli to Title VI claims. It concluded that because Title VI and the MHRA both prohibit racial discrimination by
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educational institutions, 2 the MHRA's one-year limitations period should govern claims under Title VI as well as those under Title IX.We think that the District Court's decision is inconsistent with Wilson v. Garcia, 471 U.S. 261, 105 S.Ct. 1938, 85 L.Ed.2d 254 (1985), which held that 42 U.S.C. Sec. 1983 claims are subject to the limitations period in each state's personal-injury statute. 3 In Wilson, the Supreme Court rejected the argument that Sec. 1983 claims should be governed by the period of limitations in states' civil-rights statutes. The Court held that Sec. 1983 claims are better characterized as personal-injury actions because it is unlikely that the limitations period for personal-injury actions "ever was, or ever would be, fixed in a way that would discriminate against federal claims, or be inconsistent with federal law in any respect." Id. at 279, 105 S.Ct. at 1949. The same reasoning applies to Title VI and Title IX claims.
Moreover, the District Court's decision fails to take into account the federal interest in uniformity and certainty. See id. at 275, 105 S.Ct. at 1946. "Title VI is a civil rights statute [that is] closely analogous to sections 1983 and 1981." Baker v. Board of Regents of State of Kan., 991 F.2d 628, 631 (10th Cir.1993). Indeed, a plaintiff suing a federally-supported program for racial discrimination may bring a claim under any one of these three laws. Because the Supreme Court has characterized both Sec. 1983 and Sec. 1981 as personal-injury statutes, see Goodman, 482 U.S. at 661-62, 107 S.Ct. at 2621, Title VI claims should also be governed by the limitations period in Minnesota's personal-injury...
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...of limitations applies to § 1983 claims has been the source of inconsistent rulings. Compare Egerdahl v. Hibbing Community College, 72 F.3d 615, 618 n. 3 (8th Cir.1995) (“In Minnesota, § 1983 claims are governed by the six-year limitations period of Minnesota's personal-injury statute.”); O......
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...Minnesota, 73 F.3d 816, 818-19 (8th Cir. 1996), the § 1981 claim is barred by the Eleventh Amendment, see Egerdahl v. Hibbing Cmty. Coll., 72 F.3d 615, 618-19 (8th Cir. 1995)."); Jacobsen v. DOT, 332 F. Supp. 2d 1217, 1235 (N.D. Iowa 2004) (doctrine of sovereign immunity precludes plaintiff......
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Guggenberger v. Minnesota, Civil No. 15-3439 (DWF/BRT)
...by some express statutory provision. See Will v. Mich. Dep't. of State Police, 491 U.S. 58, 66-67 (1989); Egerdahl v. Hibbing Cmty. Coll., 72 F.3d 615, 619 (8th Cir. 1995). The Supreme Court has identified a longstanding exception to Eleventh Amendment sovereign immunity, permitting suits a......
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...a state, a state instrumentality, or a state employee who is sued in his or her official capacity. See Egerdahl v. Hibbing Cmty. Coll., 72 F.3d 615, 619 (8th Cir. 1995); Dover Elevator Co. v. Arkansas State Univ., 64 F.3d 442, 446-47 (8th Cir. 1995). Only individual-capacity claims alleged ......
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Hester v. Redwood Cnty., Civil No. 11–1690 ADM/JJK.
...of limitations applies to § 1983 claims has been the source of inconsistent rulings. Compare Egerdahl v. Hibbing Community College, 72 F.3d 615, 618 n. 3 (8th Cir.1995) (“In Minnesota, § 1983 claims are governed by the six-year limitations period of Minnesota's personal-injury statute.”); O......
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Lefever v. Dawson Cnty. Sheriff's Dep't, 4:20CV3066
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Rodgers v. Univ. of Missouri Bd. of Curators, Case No. 4:11CV0515 JAR
...Minnesota, 73 F.3d 816, 818-19 (8th Cir. 1996), the § 1981 claim is barred by the Eleventh Amendment, see Egerdahl v. Hibbing Cmty. Coll., 72 F.3d 615, 618-19 (8th Cir. 1995)."); Jacobsen v. DOT, 332 F. Supp. 2d 1217, 1235 (N.D. Iowa 2004) (doctrine of sovereign immunity precludes plaintiff......
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Guggenberger v. Minnesota, Civil No. 15-3439 (DWF/BRT)
...by some express statutory provision. See Will v. Mich. Dep't. of State Police, 491 U.S. 58, 66-67 (1989); Egerdahl v. Hibbing Cmty. Coll., 72 F.3d 615, 619 (8th Cir. 1995). The Supreme Court has identified a longstanding exception to Eleventh Amendment sovereign immunity, permitting suits a......