Ottaviani v. State University of New York at New Paltz

Several female faculty members (plaintiffs) at the State University of New York at New Paltz (university) (defendant) contended that they received lower salaries than did male faculty members. The female faculty members brought suit, alleging that the university discriminated on the basis of sex in violation of Title VII of the Civil Rights Act of 1964 (Title VII). The female faculty members’ statistical expert conducted a regression analysis. The analysis identified a number of nondiscriminatory factors that could have accounted for salary differences between male and female faculty members. By identifying these nondiscriminatory factors, the statistical expert was able to predict the salaries that the female faculty members should have received. Further, the statistical expert determined that the disparity between the predicted and actual salaries of the female faculty members was more than two standard deviations. However, the university asserted that this regression analysis failed to include certain nondiscriminatory factors that were influential in the setting of faculty salaries. Additionally, the university argued that the analysis overestimated the predicted salaries of the female faculty members, such that the disparity between the predicted and actual salaries was overstated. The district court ruled in favor of the university. Specifically, the district court found that the university successfully undermined the female faculty members’ case by attacking the validity of the female faculty members’ statistical evidence. The female faculty members appealed.