Michelle Bruce v. Meharry Medical College, 692 F. App'x 275

Michelle Bruce worked at Meharry Medical College from 2005 until her resignation in 2014, serving in occupational medicine and later internal medicine with clinical, teaching, and administrative duties.
Bruce alleges that Dr. Bernard Ray (facilities) frequently belittled her at committee meetings and made a sexually suggestive remark in August 2013; she reported the remark to Meharry’s compliance hotline but received no response and did not inform her supervisor, Dr. Duane Smoot.
After a building flood, Bruce clashed with Ray over whether the space was habitable and was required to move back before she believed it was safe.
In November 2013 Smoot assigned physicians to an off-site clinic at Antioch; Bruce declined the mandatory assignment and never worked there; two male physicians were asked as well, one of whom later worked at Antioch in 2016.
Bruce resigned March 3, 2014, filed an EEOC charge, received a right-to-sue letter, and sued Meharry for sex discrimination, hostile work environment, and retaliation; the district court granted summary judgment for Meharry, and the Sixth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Gender discrimination (disparate treatment)	Ray’s disrespect, the flood dispute, and Smoot’s assignment to Antioch were adverse actions motivated by sex	Bruce suffered no adverse action (she never worked at Antioch) and presented no evidence that similarly situated males were treated differently	Judgment for employer — no prima facie case (no adverse action; no disparate treatment)
Hostile work environment	Ray’s repeated belittling at meetings and the sexually suggestive remark created an objectively hostile environment	Comments were sporadic, not physically threatening, and did not affect Bruce’s work performance	Judgment for employer — harassment not sufficiently severe or pervasive to create hostile work environment
Retaliation	Bruce’s hotline report was protected activity and Smoot’s Antioch assignment was retaliatory	Smoot did not know of Bruce’s hotline complaint; no evidence supervisors knew of the protected activity before taking action	Judgment for employer — no evidence supervisor knew of complaint, so no prima facie retaliation case

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (established burden-shifting framework for circumstantial discrimination)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment requires no genuine dispute of material fact)
Harris v. Forklift Sys., Inc., 510 U.S. 17 (factors for hostile work environment: frequency, severity, physically threatening vs. offensive utterance, effect on work)
Ondricko v. MGM Grand Detroit, LLC, 689 F.3d 642 (6th Cir.) (distinguishes direct vs. circumstantial evidence in Title VII claims)
Grace v. USCAR, 521 F.3d 655 (6th Cir. 2008) (elements of hostile work environment claim)
Regan v. Faurecia Auto. Seating, Inc., 679 F.3d 475 (6th Cir. 2012) (definition of adverse employment action)
Taylor v. Geithner, 703 F.3d 328 (6th Cir. 2013) (elements of prima facie retaliation claim)
Mulhall v. Ashcroft, 287 F.3d 543 (6th Cir. 2002) (supervisors must have known of protected activity for retaliation liability)
Carl v. Muskegon Cty., 763 F.3d 592 (6th Cir. 2014) (standards for reviewing summary judgment in employment cases)