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 their entirety, rejecting appeals from both the plaintiff-appellant and the defendant-appellee. Regarding the plaintiff’s appeal, the court held that summary judgment was properly granted on her Equal Pay Act, Title VII, and Elliott-Larsen Civil Rights Act (ELCRA) claims for sex, race, and national origin discrimination, as well as her retaliation claims, and affirmed the grant of qualified immunity to Dean Johnson. The court applied the *McDonnell Douglas* burden-shifting framework and found that the plaintiff failed to establish a prima facie case or prove pretext because she could not demonstrate that similarly situated employees outside her protected classes were treated more favorably; specifically, evidence showed her husband received higher merit raises due to superior research output and teaching evaluations. The court further ruled that temporal proximity alone was insufficient to establish causation for the retaliation claims, noting that gaps of 25 days and six weeks did not constitute “extremely close” proximity under Sixth Circuit precedent. Regarding the defendant’s appeal, the court affirmed the jury verdict finding Michigan Technological University liable for pregnancy discrimination under ELCRA. The court applied Michigan state law standards for adverse employment actions and causation, determining that a low merit raise following maternity leave constituted a materially adverse action. The court found sufficient evidence of causation where the Dean explicitly told the plaintiff that her lower raise was because she took maternity leave and failed to perform service duties that university policy required her to be relieved from performing during leave. Additionally, the court rejected arguments that the ELCRA claim was improperly pleaded due to the use of the term “gender” instead of “sex,” noting that such a distinction did not exist in the statute at the time of filing and that the complaint provided fair notice of the claim. The court also affirmed the district court’s evidentiary rulings, concluding that admitted evidence regarding rejected adverse actions and wage disparities was relevant to proving discriminatory animus and that limiting instructions adequately guided the jury. The practical consequence is that the judgment stands: the plaintiff’s federal discrimination and retaliation claims remain dismissed, Dean Johnson retains qualified immunity from liability, and the university remains liable for $205,000 in damages ($5,000 economic and $200,000 emotional distress) awarded by the jury for pregnancy discrimination under Michigan state law. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.