Dr. Kristine Yoder, an Associate Professor in the Cancer Biology and Genetics Department at Ohio State University’s College of Medicine, filed suit alleging sex discrimination, unequal pay, hostile work environment, and retaliation under Title VII and the Equal Pay Act. She claimed that she was paid less than male colleagues, subjected to dismissive treatment by department leadership, and retaliated against after raising concerns about pay disparities.
Dr. Yoder began her career at OSU in 2004 as a postdoctoral researcher and was promoted to Assistant Professor in 2012 and Associate Professor in 2020. During her tenure, she received both annual merit-based increases and a significant off-cycle raise in 2018, when her salary increased from approximately $109,000 to $130,000 after concerns were raised that her pay was below market. By 2025, her salary had increased to approximately $188,800.
Her primary comparator was Dr. Vincenzo Coppola, a male Associate Professor, who at one point earned approximately $220,000 while she earned about $159,000. Dr. Yoder argued that she outperformed him in grant funding and publications and that the disparity reflected sex-based discrimination. The University explained that Dr. Coppola’s higher pay was attributable to his additional administrative role as Director of the Genetically Engineered Mouse Modeling Core, which carried a substantial salary supplement. When that program ended in 2022, his salary was reduced, and by 2025 he earned less than Dr. Yoder.
Dr. Yoder also pointed to other incidents as evidence of discrimination and a hostile work environment, including being interrupted during meetings, receiving dismissive responses from the department chair, and experiencing delays in hiring support staff. She further alleged that after she filed internal complaints about pay disparities in 2020 and 2021, she was retaliated against, including receiving a 4% merit increase instead of a 5% increase awarded to a male colleague in 2021 and initially receiving a rating of “good” on her annual performance review.
The Court granted summary judgment in favor of the University on all claims.
With respect to the Title VII sex discrimination claim, the Court applied the McDonnell Douglas framework and found that, even assuming Dr. Yoder established a prima facie case, the University articulated legitimate, nondiscriminatory reasons for the challenged actions. The difference in merit increases was tied to specific performance metrics, including that Dr. Yoder did not perform departmental services and that the publications she submitted were of lesser scientific impact. The Court found no evidence that these reasons were false or a pretext for discrimination.
The Court likewise rejected the Equal Pay Act claim. It concluded that Dr. Yoder and Dr. Coppola did not perform substantially equal work during the relevant period because of his additional administrative responsibilities, including his role as the Director of the Mouse Core, which required significant time and effort. The Court noted that Dr. Coppola’s employment offer letter delineated that he was being hired for two separate positions, each of which carried a separate salary. The Court also held that, even if a prima facie case had been established, the pay disparity was justified by a “factor other than sex,” namely the additional role and responsibilities.
Her hostile work environment claim failed because the alleged conduct, while arguably unprofessional, was not shown to be based on gender. The Court emphasized that Title VII does not prohibit general workplace friction or discourtesy, but only conduct motivated by discriminatory animus.
Finally, the Court rejected Dr. Yoder’s retaliation claim, finding no evidence that her protected activity was the cause of the alleged adverse action. The Court noted that the merit increase decision was supported by documented performance considerations and that temporal proximity alone was insufficient to establish causation.
Accordingly, the Court granted summary judgment for the University on all claims.
Yoder v. Ohio State Univ. (S.D.Ohio Mar. 16, 2026) 2026 WL 730275.
Note: This case underscores the importance of clearly documenting compensation decisions and tying them to objective factors such as administrative responsibilities, performance metrics, and institutional service. Even relatively small pay differences can be scrutinized, and well-supported, consistently applied criteria are critical in defending against discrimination and equal pay claims.