Sweeney v. Board of Trustees of Keene State College

Christine Sweeney (plaintiff) was an assistant professor in the Department of Education at Keene State College (Keene) (defendant). In 1972 Sweeney was awarded tenure. Shortly after, Sweeney sought promotion to the position of full professor, the highest teaching rank at Keene. Such requests went through an administrative-review process, which began with the Faculty Evaluations Advisory Committee (FEAC), a five-member panel that made a recommendation to the dean. Decisions could be appealed to the Faculty Appeals Committee (FAC). Sweeney’s first request was denied by the dean after an all-male FEAC voted unanimously against the promotion but offered no reasons for its decision. Sweeney’s appeal to the FAC failed. Sweeny tried again to attain a promotion during the 1974 school year. Sweeny’s application was again voted against by an all-male FEAC. Despite a letter from the FAC describing her treatment as unprofessional, Sweeney’s second appeal also failed. Sweeney’s third try, which came during the 1975-76 school year, was successful. Sweeney brought numerous claims against Keene, its board, and its president, one of which alleged a violation of Title VII of the Civil Rights Act of 1964 (Title VII). Sweeney’s Title VII claim was premised on her allegation that she had been denied promotion because of sex discrimination. At trial, Sweeney presented a plethora of evidence, both statistical and anecdotal, highlighting the scarcity of women within full-professorship ranks at Keene. A district court ruled in favor of Sweeney on her Title VII claim, but against her on all her other claims. Keene appealed the district court’s ruling on Sweeney’s Title VII claim, and Sweeney cross-appealed.