## Facts

- Katalin Deli served as head coach of the University of Minnesota women’s gymnastics team until her employment was terminated in June 1992.
- She pursued internal grievance procedures; the University upheld the termination for just cause.
- Deli filed a federal action in October 1993 asserting compensation-based discrimination claims, not challenging the legality or justification of her discharge.
- Deli alleged the University paid her less than certain head coaches of men’s athletic teams.
- Her theory was that the pay differential was based on the sex of the athletes she coached (women), not that she was paid less because she was a woman.
- She brought claims under Title VII, the Equal Pay Act (EPA), and Title IX.
- The University moved for summary judgment on all claims.

## Issues

1. Whether Title VII prohibits compensation discrimination against an employee based on the sex of third parties (the athletes coached), rather than the employee’s own sex.
2. Whether the University violated the EPA by paying Deli less than coaches of men’s teams, or whether differences were justified by “a factor other than sex” and/or the jobs were not equal.
3. Whether Title IX provides a remedy for a coach’s compensation claim premised on the sex of the athletes coached.

## Decision

- The court granted the University’s motion for summary judgment on all claims.
- Title VII claim dismissed because the alleged discrimination was not “because of” Deli’s own sex.
- EPA claim dismissed because, even assuming a prima facie case, the University established the pay differences were attributable to non-sex factors tied to the positions.
- Title IX claim dismissed because the asserted theory—pay decisions based on athletes’ sex—did not support relief on these facts.
- The action was dismissed.

## Legal Principles

- Summary judgment is appropriate when there is no genuine dispute of material fact and the movant is entitled to judgment as a matter of law.
- Title VII compensation liability requires discrimination against an individual “because of such individual’s” sex; discrimination alleged to stem from the sex of persons supervised is not within the statute as applied here.
- Under the EPA, a plaintiff must show unequal pay for equal work requiring equal skill, effort, and responsibility under similar working conditions; an employer avoids liability by proving a statutory defense, including that the differential is based on a factor other than sex.
- Differences in program responsibilities and market-related considerations (e.g., team size, revenue generation, public exposure, supervisory burdens) can constitute “factors other than sex” supporting an EPA defense.

## Conclusion

The court held that a coach’s claim of lower pay tied to the sex of the athletes coached did not state a Title VII or Title IX compensation claim, and that any pay disparity was justified under the Equal Pay Act by non-sex factors reflecting differences in coaching positions; summary judgment was entered for the University on all counts.


Deli v. Univ. of Minn., 863 F. Supp. 958 (D. Minn. 1994)