Kunda v. Muhlenberg College

463 F. Supp. 294 (1978)

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Kunda v. Muhlenberg College

United States District Court for the Eastern District of Pennsylvania
463 F. Supp. 294 (1978)

Facts

Connie Rae Kunda (plaintiff) taught in the Physical Education Department at Muhlenberg College (Muhlenberg) (defendant). Although Muhlenberg’s official policy provided that a PhD was required for tenure, a master’s was regarded as the terminal degree needed for promotion in the Physical Education Department. Kunda was never informed of this requirement, but other teachers in the department were made aware by the dean. Kunda, who did not possess a master’s degree, filed suit against Muhlenberg after being denied tenure, alleging sex-based discrimination in violation of Title VII of the Civil Rights Act of 1964. Kunda argued that Muhlenberg’s terminal-degree requirement had a disparate impact on women and that she suffered disparate treatment on the basis of her sex. At trial, it was established that the male professors in the Physical Education Department were aware of the requirement. Muhlenberg could not offer any reason as to why it failed to inform Kunda of this requirement, even though administrators testified that they had had discussions with her about her future. There was evidence indicating that the dean had previously made employment decisions on the basis of sex.

Rule of Law

Issue

Holding and Reasoning (Huyett, J.)

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