Case Explained: 26a0272n.06

Court: United States Court of Appeals for the Sixth Circuit Filed: 2026-06-23 The Sixth Circuit affirmed the district court’s rulings in a civil rights employment case involving pregnancy discrimination claims brought by Professor Peng Guo against Michigan Technological University and Dean L. Johnson under Title VII, the Equal Pay Act (EPA), the Elliott-Larsen Civil Rights Act (ELCRA), and 42 U.S.C. § 1983. The court upheld the grant of summary judgment to defendants on Guo’s EPA, race, sex (non-pregnancy), national origin, and retaliation claims, while affirming the jury verdict in favor of Guo on her state-law pregnancy discrimination claim under ELCRA. Regarding the EPA claim, the court applied the *McDonnell Douglas* burden-shifting framework and found that while Guo established a prima facie case of wage disparity with her husband, Dean Johnson’s non-co-authored research output, the university successfully proved an affirmative defense that the pay differential was based on factors other than sex. The court determined that Eshleman’s superior publication record (five non-co-authored articles versus one for Guo) and higher teaching evaluations justified the salary difference, rendering any pretext argument insufficient as a matter of law. On the Title VII and ELCRA discrimination claims regarding race, sex, and national origin, the court applied the *McDonnell Douglas* framework to determine if Guo established a prima facie case. The court held that Guo failed to show differential treatment for adverse actions such as service requirements during leave, database cancellations, constructive discharge, or fellowship reassignments because she could not identify similarly situated comparators outside her protected classes who were treated differently. The court further ruled that her wage discrimination claims under these statutes failed because they relied on the same facts as the EPA claim, which had already been resolved in favor of the defendants via the affirmative defense. Regarding retaliation claims, the court found Guo failed to establish causation, noting that temporal proximity alone (25 days and six weeks) was insufficient to infer a causal link between her protected activity and the alleged adverse actions without additional evidence. Additionally, the court affirmed Johnson’s qualified immunity, ruling that Guo failed to identify a clearly established constitutional right violated by Johnson’s conduct. In addressing Michigan Tech’s appeal of the jury verdict on the ELCRA pregnancy discrimination claim, the court applied a de novo standard of review for the denial of judgment as a matter of law, viewing evidence in the light most favorable to the non-moving party (Guo). The court rejected the university’s argument that Guo failed to properly plead the claim, noting that her complaint provided fair notice and that the distinction between “sex” and “gender” in the ELCRA statute was not applicable at the time of filing. On the merits, the court found sufficient evidence for a reasonable jury to conclude that the low merit raise following maternity leave constituted an adverse employment action and that Dean Johnson’s direct statement attributing the low raise to her taking maternity leave established the necessary causal link for pregnancy discrimination. The court also affirmed the district court’s evidentiary rulings, finding no abuse of discretion in admitting evidence regarding wage disparities and other alleged adverse actions as proof of discriminatory animus, particularly given the limiting instructions provided to the jury. The practical consequence is that the judgment of the district court stands: Guo retains her $205,000 jury award for economic damages and emotional distress related to pregnancy discrimination under Michigan state law, while all federal claims against the university and individual liability claims against Johnson are dismissed. The case concludes with no further appellate review available on these merits. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.