She established her prima facie case and also named individual board members who were involved in the selection decision.
Affirming a district court’s denial of a motion to dismiss a Section 1983 equal protection claim alleging sex discrimination brought by Jackson State University’s vice president and chief of staff, the Fifth Circuit found that the individual defendants’ claims of qualified immunity were not enough at the summary judgment stage. The VP asserted facts establishing a prima facie case of sex discrimination and, in naming each individual defendant, had pleaded that each defendant individually caused her harm, thus adequately stating an equal protection violation (Jackson v. Duff, No. 25-60020 (5th Cir. Dec. 10, 2025)).
The plaintiff in this case has served as vice president and chief of staff at Jackson State University (JSU) since 2017.
Interim president. On February 10, 2020, JSU’s president stepped down from his role. JSU’s Board then appointed the former president’s special assistant, a male, as interim president. This appointment came despite the fact that the now interim president reported to the VP and despite the Board’s knowledge that the VP was interested in the post. Indeed, she had “regularly run” JSU when its president was absent.
The VP continued to serve in her position at the interim president’s request, who acknowledged that “he was not qualified or prepared to serve.” Soon thereafter, the Board dispensed with a national search, declined to...
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