Lan Yao v. Oakland Univ.

CourtCourt of Appeals for the Sixth Circuit
DecidedJanuary 19, 2024
Docket22-1980
StatusUnpublished

This text of Lan Yao v. Oakland Univ. (Lan Yao v. Oakland 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.

Bluebook
Lan Yao v. Oakland Univ., (6th Cir. 2024).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 24a0028n.06

Case No. 22-1980

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

FILED Jan 19, 2024 ) LAN YAO, KELLY L. STEPHENS, Clerk ) Plaintiff-Appellant, ) ) ON APPEAL FROM THE UNITED v. ) STATES DISTRICT COURT FOR ) THE EASTERN DISTRICT OF OAKLAND UNIVERSITY, ) MICHIGAN Defendant-Appellee. ) ) OPINION

Before: GRIFFIN, BUSH, and READLER, Circuit Judges.

CHAD A. READLER, Circuit Judge. Following the denial of tenure in Oakland

University’s school of nursing, Dr. Lan Yao sued the university, asserting claims of race and

national origin discrimination, as well as retaliation for filing a workplace complaint. These

theories fail. Yao has not identified a similarly situated employee who received more favorable

treatment than she, dooming her discrimination claims. Nor can she demonstrate a causal

connection between her protected activity and the university’s allegedly retaliatory action, a fact

fatal to her retaliation claim. Accordingly, we affirm the award of summary judgment in the

university’s favor.

I.

Like most departments in institutions of higher learning, Oakland University’s nursing

school employs a process for granting tenure to faculty members. Professors at the university Case No. 22-1980, Yao v. Oakland Univ.

initially serve in term-limited positions without job security, after which they are eligible for

tenure. A tenure applicant assembles a dossier documenting her qualifications. The application

is then measured by three criteria: scholarship, teaching, and professional service. Of these,

scholarship, especially “publications that have been critically evaluated,” is the most important

factor. Published work measures the candidate’s contribution to knowledge in a scholarly field.

Two committees review the application. First is the Nursing Committee, followed by the Faculty

Committee. The latter committee makes a tenure recommendation to the university based on a

review of the candidate’s qualifications. At the final stage, the university’s board of trustees, after

receiving input from the provost and president, issues a final tenure determination. Those who

unsuccessfully apply for tenure are not re-employed full time.

Now consider Yao’s journey through this process. Hailing from China, Yao was hired as

an assistant professor in the nursing school. Following a few years of service by Yao, the board

of trustees approved her reappointment to a final two-year term as an assistant professor, after

which she would be eligible for tenure. Although the Nursing Committee supported Yao’s

reappointment, it noted that she had produced no work for publication and “highly recommend[ed]

that Dr. Yao submit and have published several empirically-based manuscripts in peer-reviewed

journals” before her next review. Yet at the time of Yao’s tenure review, she had co-authored only

one peer-reviewed article since her reappointment. Both the Nursing Committee and the Faculty

Committee determined that Yao did not meet the school’s criteria for scholarship and research. In

turn, each committee voted to deny Yao tenure, a decision later ratified by the board. Yao

requested a second review. Her efforts, however, again proved unsuccessful—she was denied

tenure a second time.

2 Case No. 22-1980, Yao v. Oakland Univ.

After the university notified Yao that her employment would terminate at the end of her

contract, Yao filed discrimination charges with the Equal Employment Opportunity Commission

(EEOC), alleging both race and national origin discrimination and retaliatory conduct in violation

of Title VII of the Civil Rights Act of 1964. She later filed this suit. Ultimately, the district court

awarded summary judgment in the university’s favor. To the district court’s eye, Yao failed to

show that she was treated worse than similarly situated non-protected tenure candidates, defeating

her discrimination theories. Likewise, the court held, Yao could not establish a causal connection

between her first EEOC complaint and her eventual firing, undermining her retaliation claim.

Yao’s timely appeal followed.

II.

We review the district court’s grant of summary judgment de novo. Dixon v. Gonzales,

481 F.3d 324, 330 (6th Cir. 2007). In undertaking that fresh review, we consider the evidence in

the light most favorable to Yao, the nonmoving party. Id. Eyeing the evidence that way, summary

judgment is appropriate if there is no genuine dispute of material fact in the record, and if the

university should prevail as a matter of law. See Lemon v. Norfolk S. Ry. Co., 958 F.3d 417, 418–

19 (6th Cir. 2020); Fed. R. Civ. P. 56(a).

A. Yao first contends that issues of material fact remain concerning whether she was

impermissibly denied tenure on account of her race and national origin. Title VII declares it

unlawful “for an employer . . . to discriminate against any individual with respect to his

compensation, terms, conditions, or privileges of employment, because of such individual’s

race . . . or national origin.” 42 U.S.C. § 2000e-2(a)(1). A Title VII plaintiff may show such

discrimination with either direct or indirect evidence. Redlin v. Grosse Pointe Pub. Sch. Sys., 921

F.3d 599, 606 (6th Cir. 2019). As Yao relies on the latter, we apply the McDonnell Douglas burden

3 Case No. 22-1980, Yao v. Oakland Univ.

shifting framework to evaluate her claim. Lindsay v. Yates, 498 F.3d 434, 440 n.7 (6th Cir. 2007).

Under that construct, Yao bears the initial burden to establish a prima facie case of discrimination.

McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802 (1973).

Our focus here is on whether Yao was “treated differently than similarly situated non-

protected employees,” one element of a prima facie case. Redlin, 921 F.3d at 607 (citation

omitted); see also Newman v. Fed. Express Corp., 266 F.3d 401, 406 (6th Cir. 2001) (articulating

a four-part test). To show as much, Yao need not demonstrate an exact correlation between herself

and the allegedly similarly situated employees outside of her protected class. But, at the very least,

there must be relevant similarity between them. Blount v. Stanley Eng’g Fastening, 55 F.4th 504,

511–12 (6th Cir. 2022). Yao fails to make this showing.

Yao identifies six white comparators who, she says, were similarly situated to her and yet

were granted tenure. According to Yao, this disparity is demonstrated through peer-reviewed

publication totals. Recall that Yao had co-authored only one peer-reviewed article during her time

at the university. Yet her comparators uniformly had published relatively more journal articles.

True, the qualifying journal articles of Dr. Julie Kruse, one of Yao’s comparators, had seemingly

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