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Recently, a federal judge in Detroit has narrowed a discrimination lawsuit brought by a Black law professor against the University of Michigan Law School. The judge, U.S. District Judge David M. Lawson, dismissed claims of race, sex, and disability discrimination filed by the plaintiff, law and economics professor Laura Beny while allowing a federal retaliation claim against the university’s board of regents and a state-law retaliation claim against the law school dean, Mark D. West.
The retaliation claims stem from Beny’s allegations that her teaching duties, committee-service duties, salary, and benefits were suspended shortly after she made an internal bias complaint. Judge Lawson acknowledged that Beny could proceed with the retaliation claims, as her complaint suggested that the actions taken against her directly resulted from her filing the bias complaint.
Among the various allegations made by Beny, she claimed to have received inappropriate emails from Dean West during his tenure as associate dean. Additionally, she asserted that she was paid less than her colleagues in the same cohort, deprived of comparable career opportunities, and that white professors were granted greater flexibility in teaching via Zoom. Beny also alleged that she was falsely accused of misconduct in an attempt to tarnish her reputation, and she faced disciplinary action for behavior that white professors engaged in without repercussions. Furthermore, she stated that her teaching responsibilities and other benefits were suspended when she filed a complaint with the university. Although the salary discrepancy was later acknowledged as a mistake and rectified with back pay, the overall impact on Beny’s professional life and well-being was significant.
Beny, who is a single mother, took three medical leaves during her employment. The first occurred in 2017 due to the toll of a hostile work environment, while the second, in 2019, was attributed to work-related psychological trauma. The third leave, taken in February 2022, was a result of extreme psychological distress following an anonymous student complaint that Beny claimed was false. As a consequence of these challenges, she has not returned to the classroom.
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Judge Lawson dismissed the majority of Beny’s claims on several grounds. These included 11th Amendment immunity for the university regents regarding state law claims in federal court, the inability to sue Dean West in his individual capacity for certain claims under Title VII of the Civil Rights Act, and the insufficient presentation of facts to establish discrimination or a hostile work environment.
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Regarding the allegations of discrimination based on race, gender, or family status, Judge Lawson found that Beny had not provided sufficient factual evidence to support her claims. The judge emphasized that mere assertions of differential treatment compared to white, male, or married colleagues were inadequate to establish intentional discrimination. While disparate treatment of similarly situated individuals could potentially suggest discrimination, Beny failed to identify specific individuals who were treated more favorably during the relevant period, only alleging their existence.
Addressing Beny’s claims of a hostile work environment, Judge Lawson concluded that the alleged harassment did not meet the threshold of being sufficiently severe or pervasive to create an abusive working environment. The judge noted that Beny’s contentions mainly revolved around being treated differently than her colleagues and falsely accused of misconduct, which, although personally frustrating, did not meet the demanding standards for judging hostility under Title VII.
As the case progresses, the focus will now primarily be on the remaining retaliation claims against the university’s board of regents and the law school dean. The outcome of this lawsuit will have implications not only for the parties involved but also for broader discussions surrounding discrimination, retaliation, and workplace dynamics within academic institutions.
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