Background
Peng Guo, a Chinese-born professor at Michigan Technological University, sued the university and Dean L. Johnson alleging discrimination based on pregnancy, sex, race, and national origin, as well as retaliation and an Equal Pay Act violation. A jury found the university liable for pregnancy discrimination under the Elliott-Larsen Civil Rights Act but not under Title VII, awarding Guo five thousand dollars in economic damages and two hundred thousand dollars for emotional distress. The district court had previously granted summary judgment on federal discrimination, retaliation, and Equal Pay Act claims, and granted the dean qualified immunity. Both parties appealed the district court’s rulings.
The court’s reasoning
The Sixth Circuit reviewed the appeals separately. On Guo’s appeal, the court affirmed summary judgment on her Equal Pay Act claim, finding the university proved the pay disparity was based on research output and teaching evaluations rather than sex. The court also affirmed summary judgment on federal sex, race, and national origin discrimination claims, noting Guo failed to show differential treatment for most alleged adverse actions and that her wage claim failed because the university established an affirmative defense under the Equal Pay Act. The court affirmed summary judgment on retaliation claims, finding insufficient causal link between her complaints and the adverse actions. Finally, the court affirmed qualified immunity for the dean, ruling Guo failed to identify a clearly established constitutional rule prohibiting the dean’s conduct. On the university’s appeal, the court affirmed the jury verdict on the state law pregnancy discrimination claim, finding the low merit raise after maternity leave was an adverse action and that the dean’s statement linking the raise to her leave established causation.
Because the district court did not err in its rulings, we AFFIRM across the board.
What it means going forward
The decision reinforces that while state law may allow pregnancy discrimination claims to proceed to a jury based on specific evidence of causation, federal wage discrimination claims often fail if the employer can demonstrate legitimate, non-discriminatory factors like research output justify pay differences. It also confirms that qualified immunity remains a robust defense for officials unless plaintiffs can point to highly specific, clearly established case law.