Cullen v. Indiana University Board of Trustees

Deborah Cullen (plaintiff) was the director of the Respiratory Therapy Program at Indiana University. Cullen, who held a bachelor’s degree in respiratory therapy, a master’s degree in education, and a Doctor of Education degree, was hired in 1990 at a salary of $45,000. Cullen obtained tenure and was promoted to full professor, and in 1997 her salary was $62,000. In July 1998, Sandy Quillen was hired as program director of physical therapy and as a tenured professor at a salary of $90,000. Quillen held five degrees, including a Ph.D. in sports medicine. When Quillen was hired, the physical-therapy program was in danger of losing its accreditation, and Quillen was required to not only save the program from its probationary status, but also launch a graduate program. Quillen’s physical-therapy program was significantly larger than the respiratory-therapy program: it accounted for nearly 30 percent of the tuition revenue for the School of Allied Health Sciences, of which physical therapy and respiratory therapy were both a part. The respiratory-therapy program garnered significantly less tuition revenue than the physical-therapy program. The two professors’ salaries were as follows: in 1998–99, Cullen’s was $63,240 and Quillen’s was $90,000; in 1999–00, Cullen’s was $67,114 and Quillen’s was $93,150; in 2000–01, Cullen’s was $68,121 and Quillen’s was $94,547; and in 2001–02, Cullen’s was $70,505 and Quillen’s was $97,856. Cullen sued the Indiana University Board of Trustees (university) (defendant), alleging that the discrepancies between her and Quillen’s salaries violated the Equal Pay Act (EPA). The district court granted summary judgment in favor of the university. Cullen appealed.