Court Case: Fields v. Clark University

Case History

Rona Fields, former associate professor of sociology at Clark University in Massachusetts, sued the university for sex discrimination in the denial of tenure in violation of Title VII of the Civil Rights Act of 1964.

Fields, an expert on intergenerational and intercommunal violence, joined Clark’s sociology department in 1972 as an associate professor. At the time of her hire and throughout her employment at Clark, she was the only female faculty member in her department. Fields alleged that from the beginning of her employment, male faculty members within the department subjected her to various forms of sex discrimination such as sexual innuendos, sexual harassment, and denigration of her professional status. She also stated that one male faculty member, who had made sexual advances towards her, told her that her refusal of his advances was “no way to get tenure.” Beginning in 1974, Fields filed a series of complaints of sex discrimination with the university’s affirmative action officer. She stated that despite these complaints, the sex discrimination continued throughout her employment.

In fall 1974, the department faculty reviewed Fields’ tenure application and unanimously recommended that she be denied tenure, which the board of trustees ultimately affirmed. Fields maintained that the faculty’s decision was based largely on a few negative student evaluations from courses she had taught. She alleged in part that the weight given to these evaluations in her tenure review differed greatly from that given in recent tenure reviews of her male colleagues, in which none were denied tenure despite negative student evaluations. Fields appealed her tenure denial internally to know avail and received a terminal contract that ended in 1976.

That year, Fields filed a complaint with the Equal Employment Opportunity Commission against Clark, alleging sex discrimination in employment. The EEOC issued a determination in 1979, finding probable cause to believe that Fields’ allegations were true. Fields filed a complaint against Clark in federal court shortly thereafter. After a bench trial, the court determined that though Fields had not proved that she would have been qualified to receive tenure, she did prove by preponderance of the evidence that her tenure denial was “impermissibly infected with sexual discrimination,” which entitled her to relief under Title VII. The court ordered Clark to pay Fields back salary and reinstate her on a probationary basis for two years, at the end of which the university would reconsider her for tenure.

Clark appealed the decision to the U.S. Court of Appeals for the Second Circuit, which vacated the lower court’s decision in 1987 and remanded the case for a new trial before a new judge. In its decision, it stated that the lower court erred by ordering the university to reinstate Fields without a finding that she would have been granted tenure in the absence of sex discrimination. In the new trial, which took place roughly three years later, the court found in favor of the university. Fields’ unsuccessfully appealed the decision to the Second Circuit. She then appealed to the U.S. Supreme Court, which in 1993 declined to hear her case.

Key Issues

Sex discrimination in the denial of tenure in violation of Title VII of the Civil Rights Act of 1964.