Lee v. Howard Hughes Medical Institute, 607 F.Supp.3d 52

Dr. Jeannie T. Lee, an Asian‑American physician/scientist, served as an HHMI Investigator based at Massachusetts General Hospital from 2000 and was renewed twice (2006, 2011) but not renewed in 2016 for a fourth five‑year term.
HHMI’s renewal process used external advisory panelists who reviewed written materials, heard a 35‑minute oral presentation, and submitted confidential letter grades (A/B/C); Institute leadership then recommended to the President who made the final renewal decision.
In September 2016 Dr. Lee received 11 B scores and 7 C scores (no A’s); reviewers criticized the rigor of her models and research; HHMI leadership recommended non‑renewal and the President declined to reappoint her.
Separately, Dr. Lee asserted she had been underpaid relative to MGH colleagues; HHMI increased her salary in 2016 after an MGH equity review but did not implement the larger adjustment MGH initially requested.
Procedural posture: Dr. Lee filed MCAD and then court claims alleging (1) discriminatory non‑renewal (M.G.L. c. 151B), (2) salary discrimination (M.G.L. c. 151B), and (3) Massachusetts Equal Pay Act (M.G.L. c. 149, § 105A). HHMI moved for summary judgment; the court allowed the motion in full.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Discriminatory non‑renewal under M.G.L. c. 151B	Lee: advisory panel’s scores/comments reflected unconscious bias against her (gender/race/national origin); non‑renewal was tainted	HHMI: decision based on legitimate, non‑discriminatory scientific judgments and low reviewer scores	Court: Lee made a prima facie showing but HHMI offered a legitimate reason; Lee failed to show pretext (no evidence of discriminatory motive). Summary judgment for HHMI
Salary discrimination (Chapter 151B) — timeliness	Lee: claim accrued Jan 2017 when she saw MGH salary study redaction	HHMI: accrual at or before Aug 2016 (email notifying equity‑based raise) — MCAD filing July 2017 was untimely	Court: accrual no later than Aug 2016; Chapter 151B claim time‑barred. Summary judgment for HHMI
Massachusetts Equal Pay Act (MEPA) — timeliness & merits	Lee: MEPA claim limited to July–Sept 2018 paychecks (post‑amendment) and thus timely; paid less than male Investigators	HHMI: earlier MEPA limitations apply; also no proper comparable Investigator or proof of comparable work	Court: post‑July 1, 2018 paychecks are timely under amended MEPA, but Lee offered no adequate comparator evidence or proof of comparable job content — MEPA claim fails. Summary judgment for HHMI

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden‑shifting framework for disparate‑treatment claims)
Villanueva v. Wellesley College, 930 F.2d 124 (1st Cir. 1991) (adapted prima facie/pretext rules for tenure‑style decisions)
Thiedon v. Harvard Univ., 948 F.3d 477 (1st Cir. 2020) (pretext requires minimally sufficient evidence to avoid summary judgment)
Silvestris v. Tantasqua Reg’l Sch. Dist., 847 N.E.2d 328 (Mass. 2006) (pay claims accrue at each paycheck; discovery rule principles)
Jancey v. School Comm’n of Everett, 658 N.E.2d 162 (Mass. 1995) (test for job comparability under MEPA)
Jancey v. School Comm’n of Everett, 695 N.E.2d 194 (Mass. 1998) (application of comparability analysis)
Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment burden shifting)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (standard for genuine issue of material fact)
Gu v. Boston Police Dep’t, 312 F.3d 6 (1st Cir. 2002) (MEPA requires proof of comparable work)
Brown v. Trustees of Boston Univ., 891 F.2d 337 (1st Cir. 1989) (courts should not act as super‑tenure committees)