Dr. Peng Guo, a Chinese-born accounting professor at Michigan Technological University, sued the University and the Dean of its College of Business, alleging discrimination based on pregnancy, sex, race, and national origin, along with retaliation and Equal Pay Act violations. Dr. Guo and her husband, who was also hired by the University as a tenure-track accounting professor, began employment at the same salary in 2015. Although they initially progressed through the tenure process together, Dr. Guo alleged that after she became pregnant and took maternity leave, she received lower merit raises, was expected to perform service work during leave, lost professional opportunities, and was treated less favorably than her husband and other faculty members.
Michigan Tech’s parental leave policy allowed tenure-track faculty to take either one semester of paid leave while remaining responsible for only 50% of their research obligations, or six weeks of paid leave while being relieved of all duties. The policy was silent as to service requirements. Dr. Guo selected the first option. Nevertheless, during her maternity leave, Dr. Guo continued receiving committee emails requesting that she organize academic seminars, attended her annual review shortly after giving birth by emergency C-section, and testified that the Dean remarked she had “lots of free time” because she had been relieved of teaching responsibilities. The Dean also criticized her service during the leave period, despite the Dean having been advised by the Provost that faculty taking this type of leave should not be expected to perform service obligations.
Following her return, Dr. Guo received a merit raise of 1.13%, while her husband received 2.24%. When she asked the Dean why her increase was significantly lower, Dr. Guo testified that he responded it was because she “took maternity leave” and “didn’t do enough service.” Afterward, she sent the Dean an email memorializing that conversation and asking him to correct her if she had misunderstood his comments. He never responded.
Dr. Guo also alleged that the University discriminated against her in other ways, including providing lower compensation than her husband, assigning additional responsibilities, canceling research database subscriptions, replacing her as the recipient of a faculty fellowship, criticizing her performance, and retaliating after she complained internally about discrimination. The trial court dismissed those claims on summary judgment, leaving only her pregnancy discrimination claims for trial. A jury ultimately found in her favor on her pregnancy discrimination claim under Michigan law, awarding $5,000 in economic damages and $200,000 in emotional distress damages, while rejecting her Title VII pregnancy discrimination claim. Both sides appealed.
The Sixth Circuit first affirmed dismissal of Dr. Guo’s Equal Pay Act claim. Although she established that she and her husband performed substantially equal work while he ultimately received higher merit raises, the Court concluded that the University demonstrated the pay differential resulted from factors other than sex. The evidence showed that Dr. Guo’s husband had significantly more publications, published in higher-ranked journals, and consistently received stronger teaching evaluations. Dr. Guo failed to produce sufficient evidence that those explanations were pretextual.
The Court likewise affirmed dismissal of Dr. Guo’s race, national origin, sex discrimination, and retaliation claims. It concluded that many of the alleged adverse actions either lacked appropriate comparators or failed to establish a causal connection to her protected activity. The Court further held that the individual Dean was entitled to qualified immunity because Dr. Guo failed to identify clearly established constitutional law prohibiting the conduct she alleged.
The Court reached a different conclusion regarding the jury’s pregnancy discrimination verdict. Under Michigan law, pregnancy discrimination constitutes sex discrimination. Viewing the evidence in the light most favorable to the jury’s verdict, the Court held that sufficient evidence supported the finding that the University’s decision regarding Dr. Guo’s 2017 merit raise was motivated by her pregnancy and maternity leave. Most significantly, the jury was entitled to credit Dr. Guo’s testimony that the Dean explicitly told her that her lower merit raise resulted from taking maternity leave and failing to perform service work during that leave—even though the University’s own policy did not require faculty on parental leave to perform service obligations and the provost informed the Dean that Guo was to be relieved of her service duties on leave. The Court concluded that this testimony alone provided sufficient evidence for a reasonable jury to find pregnancy discrimination.
Accordingly, the Sixth Circuit affirmed both the dismissal of Dr. Guo’s other claims and the jury’s pregnancy discrimination verdict.
Peng Guo v. Mich. Tech. Univ. (6th Cir. 2026) 2026 LX 344362.
Note: This case illustrates that managers should exercise caution when discussing the impact of protected leave on performance evaluations, compensation, or advancement. Comments directly linking an employment decision to pregnancy leave may provide compelling evidence of pregnancy discrimination.