Ren v. The University of Houston at Victoria, 4:17-cv-00444

Plaintiff Luh Yu Ren, a 64-year-old Chinese male associate professor at University of Houston–Victoria (UH Victoria), alleges Title VII claims for national origin and gender discrimination and retaliation based on workplace treatment and two EEOC charges (2012, amended 2016).
Ren had a history of frequent, hostile email campaigns and complaints about colleagues and administrators; colleagues and administrators described him as disruptive.
Ren consistently received low annual faculty evaluation scores (lowest in his school) over multiple years; merit raises were tied to those evaluations and were variable depending on available funds.
Ren alleges adverse acts including failure to promote, lower evaluations/merit raises, partial travel-funding denials, plagiarism-related scrutiny, course cancellations/assignments, and being assigned to a remote campus.
The magistrate judge considered Defendants’ summary-judgment motion and objections to portions of Ren’s evidence; some evidentiary objections were sustained, others were considered or overruled as moot.
The magistrate judge recommended granting summary judgment for Defendants, concluding Ren failed to show (1) adverse employment actions for discrimination claims and (2) a prima facie retaliation case or pretext for nondiscriminatory reasons.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness of suit	Ren filed within 90 days of right-to-sue letter; suit timely	Defendants argued untimely	Held: Ren filed within 90 days; timely.
National-origin and gender discrimination: adverse action	Ren says failures to promote, lower evaluations, pay, assignments, travel denials, plagiarism scrutiny were adverse	Defendants say none are "ultimate employment decisions" (no discharge, hire, promotion, etc.) and many are non-actionable or undocumented	Held: Ren failed to show an adverse employment action sufficient for Title VII discrimination claims.
Failure-to-promote (discrimination & retaliation contexts)	Ren contends it was futile to apply because of retaliation/discrimination	Defendants: Ren did not apply, no evidence of a consistently enforced discriminatory policy	Held: Ren did not apply or show a consistent policy of deterrence; claim fails.
Retaliation: causation and materially adverse acts	Ren cites EEOC filings as protected activity; points to lower scores/raises, travel, course cancellations, plagiarism inquiry, assignments as materially adverse and causally linked	Defendants: many incidents predate EEOC charges, are not materially adverse, were procedurally proper, or have legitimate nondiscriminatory explanations (budget, FDEP criteria)	Held: Only EEOC filings were protected activity; Ren failed to show materially adverse actions causally linked to filings or rebut Defendants’ legitimate reasons; retaliation claim fails.

Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (movant’s summary-judgment burden and when judgment is appropriate)
Anderson v. Liberty Lobby, 477 U.S. 242 (1986) (summary-judgment standard re: genuine issues of material fact)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden-shifting framework for discrimination claims)
Desert Palace, Inc. v. Costa, 539 U.S. 90 (2003) (modification of McDonnell Douglas regarding proof of discrimination)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (2000) (false employer explanation can support inference of discrimination)
Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53 (2006) (standard for materially adverse action in retaliation claims)
Univ. of Texas Sw. Med. Ctr. v. Nassar, 570 U.S. 338 (2013) (retaliation requires but-for causation)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (court may grant summary judgment when record could not lead a rational trier of fact to find for nonmovant)