Background
Peng Guo, a Chinese-born professor at Michigan Technological University, sued the university and Dean L. Johnson alleging discrimination based on sex, race, national origin, and pregnancy, as well as retaliation. A jury found the university liable for pregnancy discrimination under the Michigan Elliott-Larsen Civil Rights Act but not under Title VII. The district court had previously granted summary judgment on federal claims and granted qualified immunity to the dean. Both parties appealed the district court’s rulings.
The court’s reasoning
The Sixth Circuit reviewed the appeals de novo. On the Equal Pay Act and federal discrimination claims, the court found that the university provided legitimate, non-discriminatory reasons for the pay disparity between Guo and her husband, including superior research output and teaching evaluations by the husband. The court held that Guo failed to prove pretext. Regarding retaliation, the court found that the temporal proximity between Guo’s complaints and the alleged adverse actions was not sufficiently close to establish causation. On qualified immunity, the court agreed that Guo failed to show that the dean violated a clearly established constitutional right. On the state law pregnancy claim, the court found that the university’s failure to grant a merit increase following maternity leave, coupled with the dean’s statement that the low raise was due to her leave, constituted an adverse action with a causal link to pregnancy discrimination.
Because the district court did not err in its rulings, we AFFIRM across the board.
What it means going forward
The decision reinforces that employers may justify pay disparities with legitimate performance factors even when a plaintiff alleges discrimination, provided the plaintiff cannot prove pretext. It also clarifies that temporal proximity alone is rarely sufficient to prove retaliation and that qualified immunity remains a robust defense for officials unless the specific constitutional violation is clearly established.