Emanuelle Oliveira-Monte v. Vanderbilt Univ.

CourtCourt of Appeals for the Sixth Circuit
DecidedJune 4, 2025
Docket24-5768
StatusUnpublished

This text of Emanuelle Oliveira-Monte v. Vanderbilt Univ. (Emanuelle Oliveira-Monte v. Vanderbilt Univ.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Emanuelle Oliveira-Monte v. Vanderbilt Univ., (6th Cir. 2025).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 25a0273n.06

No. 24-5768

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Jun 04, 2025 EMANUELLE K.F. OLIVEIRA-MONTE, Ph. D., ) KELLY L. STEPHENS, Clerk ) Plaintiff-Appellant, ) ) ON APPEAL FROM THE v. ) UNITED STATES DISTRICT ) COURT FOR THE MIDDLE VANDERBILT UNIVERSITY, ) DISTRICT OF TENNESSEE Defendant-Appellee. ) ) OPINION )

Before: WHITE, LARSEN, and MURPHY, Circuit Judges.

LARSEN, Circuit Judge. Emanuelle Oliveira-Monte is a tenured Associate Professor in

the Department of Spanish and Portuguese at Vanderbilt University. In 2019, she applied for

promotion to full Professor. Vanderbilt denied her application because it judged her scholarship

record insufficient in both quantity and quality. Oliveira-Monte, who has Multiple Sclerosis, then

sued the school, alleging that Vanderbilt discriminated against her on the basis of her disability.

The district court granted summary judgment to Vanderbilt. We AFFIRM.

I.

Vanderbilt hired Oliveira-Monte in 2002 as an Assistant Professor of Portuguese. In 2008,

the University promoted her to Associate Professor and granted her tenure. Oliveira‑Monte was

granted medical leave for the academic year of 2014-2015. While on medical leave, Oliveira-

Monte was diagnosed with Relapsing-Remitting Multiple Sclerosis. After her diagnosis, she No. 24-5768, Oliveira-Monte v. Vanderbilt Univ.

requested and was granted parental leave for the fall 2015 semester and medical leave during the

fall 2017 semester. In 2019, Oliveira-Monte applied for promotion to full Professor.

Like most universities, Vanderbilt has several levels of professorial rank. Both Associate

Professors and full Professors hold academic tenure. To obtain promotion from Associate to full

Professor, Vanderbilt considers a candidate’s research, teaching, and service record:

Vanderbilt expects the level and quality of achievement in (1) research, scholarship, or creative expression; (2) teaching; and (3) service to be equivalent to that required of Professors in leading departments and schools of other major research universities. The candidate must have attained national or international recognition among leading scholars in their/his/her discipline for sustained and excellent research, must have taught the courses requested by the department or school at a consistently high level of effectiveness, and must have demonstrated a well-developed and recognized record of service both to the University and their discipline.

Id. at 968.

The review process for promotion to full Professor is multi-tiered. First, the full Professors

in the candidate’s department must vote in favor of promotion. The department’s recommendation

is then forwarded to the appropriate Dean. In the College of Arts and Sciences—Oliveira-Monte’s

college—the Senior Advisory Review Committee (SARC), composed of representatives from

various departments within the college, also reviews the candidate’s file. SARC does not vote or

make a formal recommendation, but the Dean uses SARC’s assessment to inform his own decision.

An application may move forward only if the Dean (subject to a two-thirds veto by the

department’s full Professors) concurs in the department’s positive recommendation. When a Dean

recommends promotion, that decision is then reviewed by the Promotion and Tenure Review

Committee (PTRC) and the Provost. Promotion requires the signoff of both. If a candidate clears

each level of review, the Chancellor, upon the Provost’s recommendation, promotes the candidate.

-2- No. 24-5768, Oliveira-Monte v. Vanderbilt Univ.

Vanderbilt requires candidates to submit various documents in their promotion application,

including a curriculum vitae, a teaching summary, course evaluations, and a “statement of

endeavors” describing the candidate’s “teaching philosophy and research objectives.” R. 53-8,

Guidelines and Call, PageID 984–89. Candidates must also submit a list of external reviewers.

The external reviewers, some chosen by the candidate herself and others by the candidate’s

Department Chair, then submit “letters of evaluation” to the university. Id. at 989. Vanderbilt

requires at least six letters and prefers that reviewers be “leading scholars . . . who hold the rank

of full professor at top institutions” in the candidate’s field. Id. at 989–90.

After applying for promotion to full Professor, Oliveira-Monte passed the first level of

review: the full Professors in her department unanimously voted to recommend her for promotion.

Her application then went to SARC and John Geer, Dean of the College of Arts and Sciences.

There, her application faltered. SARC commented positively on her teaching and service

records, noting that Oliveira-Monte “continues to be highly effective” as a teacher and that her

service record was “appropriate for promotion to professor.” R. 54-33, SARC Mem., PageID

2017. However, the Committee deemed her productivity as a scholar “thin” and described the

external reviewers’ reception to her most recent book as “lukewarm at best.” Id. The Committee

also discussed “whether this promotion was a bit premature.” Id.

Dean Geer then denied Oliveira-Monte a promotion. He concluded that Oliveira-Monte

“has not satisfied the standard for ‘excellence in research.’” R. 54-34, Geer Mem., PageID 2023.

Geer based that conclusion on the quantity and quality of Oliveira-Monte’s scholarly record.

First, Dean Geer questioned the quantity of her post-tenure scholarly output. By the time

she applied for promotion to Professor, she had published two books: Writing Identity: The

Politics of Contemporary Afro-Brazilian Literature (2007) and Barack Obama is Brazilian: (Re)

-3- No. 24-5768, Oliveira-Monte v. Vanderbilt Univ.

Signifying Race Relations in Contemporary Brazil (2018). She had also published eight journal

articles, five book chapters, two book reviews, and a translation. But many of those publications

predated her award of tenure in 2008. Since being granted tenure, she had published one book,

one journal article (with a second forthcoming), and several book chapters.

Dean Geer described Oliveira-Monte’s post-tenure “research productivity” as “low.” R.

54-34, Geer Mem., PageID 2020. He based that determination in part on the external reviews.

Multiple external reviewers characterized Oliveira-Monte’s post-tenure production as somewhat

lacking. One described her post-tenure output as “relatively small” and “considerably inferior” to

her pre-tenure output. R. 54-20, External Review Ltr. 3, PageID 1902. Another said her

post-tenure output was “not extensive.” R. 54-24, External Review Ltr. 7, PageID 1918.

Moreover, Geer pointed to lengthy gaps between her most recent articles. In 2008, Oliveira-Monte

published an article in the Vanderbilt EJournal of Luso-Hispanic Studies. Oliveira-Monte next

published an article five years later, in 2013, in the Luso-Brazilian Review. Geer further noted the

“large gap” between her 2013 article and a then-forthcoming article with the Hispanic Review. R.

54-34, Geer Mem., PageID 2020.

Second, Dean Geer questioned the quality of Oliveira-Monte’s scholarship. His analysis

mainly focused on Oliveira-Monte’s most recent book, Barack Obama is Brazilian. Reading

Oliveira-Monte’s external reviews, he deduced that the book was of “uncertain quality.” Id. He

noted that none of Oliveira-Monte’s reviewers offered “strong and/or detailed praise for the book,”

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