Kow-Ching Chang v. Mississippi State University

CourtDistrict Court, N.D. Mississippi
DecidedApril 23, 2026
Docket1:25-cv-00017
StatusUnknown

This text of Kow-Ching Chang v. Mississippi State University (Kow-Ching Chang v. Mississippi State University) is published on Counsel Stack Legal Research, covering District Court, N.D. Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kow-Ching Chang v. Mississippi State University, (N.D. Miss. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF MISSISSIPPI OXFORD DIVISION

KOW-CHING CHANG PLAINTIFF

v. CIVIL NO.: 1:25-cv-0017-MPM-RP

MISSISSIPPI STATE UNIVERSITY DEFENDANT

ORDER This cause comes before the court on the motion of defendant Mississippi State University (MSU) to dismiss the claims against it on summary judgment, pursuant to Fed. R. Civ. P. 56. The pro se plaintiff Kow-Ching Chang has responded in opposition to the motion, and the court, having considered the memoranda and submissions of the parties, is prepared to rule. This is a Title VII national origin discrimination and retaliation action involving administrative actions taken by MSU against plaintiff based on what it found to be instances in which he bullied and behaved in an unprofessional manner towards individuals under his supervision. Chang, a 72-year-old Taiwanese-American male, is employed by MSU as a tenured Professor within the MSU Coastal Research and Extension Center’s (“the Center”) Experimental Seafood Processing Laboratory. (“the Seafood Lab”) [Compl. at p. 6.] Although Chang remains an MSU employee today, he filed this lawsuit based primarily upon a decision to remove him as the Seafood Lab’s Director and to otherwise restrict his supervisory activities. MSU contends that its decision to remove plaintiff from this position resulted from the fact that “a number of people under Chang’s supervision have made serious complaints about Chang regarding alleged aggressive and, at times, abusive tendencies.” [Brief at 1-2]. While plaintiff appears to acknowledge that complaints were, in fact, made against him, he insists in his complaint that “all behavioral allegations were not factual and [were] only compiled after I submitted the internal discrimination claims.” [Complaint at 11].

This court notes that, in a June 10, 2025 order, it dismissed the ADEA age discrimination claim asserted by plaintiff on the basis of the Eleventh Amendment immunity enjoyed by MSU as an “arm of the state.” In so ruling, this court wrote that: It is well settled that MSU is an arm of the State of Mississippi, and, as such, the Fifth Circuit has held that it is fully entitled to assert Eleventh Amendment immunity. Jagandan v. Giles, 538 F.2d 1166, 1173-78 (5th Cir. 1976). Moreover, the U.S. Supreme Court made it clear in Kimel v. Fla. Bd. of Regents, 528 U.S. 62, 91 (2000) that Congress did not abrogate Eleventh Amendment immunity by enacting the ADEA. Finally, the Fifth Circuit has specifically found that the State of Mississippi has not waived its Eleventh Amendment immunity with respect to the ADEA. McGarry v. Univ. of Miss. Medical Center, 355 Fed. App’x 853, 856 (5th Cir. 2009), citing Miss. Code. Ann. § 11– 46–5(4) (“Nothing contained in this chapter shall be construed to waive the immunity of the state from suit in federal courts....”). Considered together, this precedent makes it clear that plaintiff’s ADEA claims in this case are barred by Eleventh Amendment immunity.

[Slip op. at 3]. While dismissing plaintiff’s ADEA claim, this court determined that it should wait until the presentation of evidence developed during discovery to address the merits of his Title VII discrimination and retaliation claims. That discovery has been completed, and this court now turns to the merits of the summary judgment issues relating to plaintiff’s Title VII claims. While it is clear that plaintiff’s decision to assert Title VII claims allows him to bypass Eleventh Amendment immunity, see Fitzpatrick v. Bitzer, 427 U.S. 445 (1976), this court notes that sovereign immunity continues to cast a shadow over the arguments and claims which he is able to make in this case. For example, plaintiff takes issue in his briefing with the procedures followed by defendant in taking disciplinary action against him, but such arguments are generally made in the context of a procedural due process claim asserted under 42 U.S.C. § 1983. Asserting such a procedural due process claim against MSU is not an option for Chang, however, since the law is clear that § 1983 claims are, like his ADEA claim, barred by Eleventh Amendment immunity. See Quern v. Jordan, 440 U.S. 332 (1979).

That leaves Title VII as plaintiff’s sole available remedy against MSU, but this court must wonder whether plaintiff’s decision to assert a Title VII discrimination claim reflected a genuine belief on his part that he was discriminated against on the basis of his Asian ancestry or whether it simply reflects a realization on his part that he had no other legal claim available to him against MSU. In so stating, this court notes its belief that, on a common-sensical level, plaintiff’s ADEA claim was considerably more plausible, on its face, than his Title VII discrimination claim. This is largely because plaintiff was a seventy-year old man during the relevant events in this case, and he had obviously gotten older during his tenure at MSU. This court believes that individuals in their seventies do frequently face workplace discrimination, and, were it not for the Eleventh Amendment’s bar, it might well have initially wondered whether age was a factor in the treatment he received in this case.1 This same initial appearance

of plausibility does not extend to plaintiff’s Title VII national origin claim. Indeed, MSU was well aware that plaintiff was of Asian descent when it hired him, and, that being the case, any argument that the treatment he received was based on his ancestry faces serious plausibility concerns. This is particularly true considering that, as discussed below, most of the co-workers whom plaintiff is alleged to have bullied were likewise of Asian descent.

1 This court hastens to add that any such initial suspicions would have been quickly dispelled once it reviewed the evidence of misconduct against plaintiff, discussed below. Having reviewed the record in this case, this court has no reason to suspect that MSU had any reluctance to hire individuals of Asian descent to work at the Center, indeed, the record rather strongly suggests otherwise. Moreover, the record includes very strong proof of misconduct on the part of plaintiff in his supervision of lab employees, so much so that this court

frankly wonders why it took MSU so long to remove his supervisory authority. In describing its proof in this regard, MSU writes in its brief that: Almost immediately after Chang became Director of the Seafood Lab, MSU began to receive complaints about his conduct. In April 2018, less than three months after Chang’s service began, Marla Lacy (a White female) contacted Dr. James Henderson, the Head of the Center, to complain that she did not feel safe being around Chang. Lacy described working with Chang as “like being in a mentally abusive relationship, only it is my boss who is the aggressor” [sic] and stated that she could “only explain [Chang’s conduct] as being[] dictator like,” adding that her “only wish is to feel safe at work.” Ex. 1, Henderson Dec., ¶ 5; Ex. 6, Apr. 20, 2018 Lacy Email. Ten days later, Lacy resigned her position rather than face Chang’s continued aggression. Ex. 7, Apr. 30, 2018 Lacy Resignation.

[Brief at 3]. MSU has submitted a copy of the April 20, 2018 email which Lacy sent to Henderson, and it fully supports defendant’s description of the evidence.

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Kow-Ching Chang v. Mississippi State University, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kow-ching-chang-v-mississippi-state-university-msnd-2026.