Zhao v. Rensselaer Polytechnic Institute
1:24-cv-00703
| N.D.N.Y. | Aug 13, 2025Background
- Plaintiff, Tianqi Zhao, a Ph.D. candidate at Rensselaer Polytechnic Institute (RPI), sued RPI for alleged violations of Title VII of the Civil Rights Act, claiming discrimination based on race and national origin.
- Zhao's enrollment at RPI included tuition remission and an academic stipend, both contingent on academic progress and student status.
- In 2022, Zhao was placed on probation and then interim suspension following an anonymous harassment complaint by a staff member; her externship at IBM was consequently canceled.
- Disciplinary proceedings were initiated against Zhao, but prior to their resolution, she withdrew from the Ph.D. program and graduated with a master’s degree instead.
- Zhao alleged she was presumed guilty and disciplined due to racial bias, specifically because she is Chinese and the complaint originated from a white staff member.
- RPI moved to dismiss the complaint for failure to state a claim, also seeking to stay discovery pending dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Title VII Applicability to Student Role | Zhao is covered by Title VII due to her dual status as student and paid teaching/extern position. | Actions were related to Zhao's student status, outside Title VII's scope. | Assumed applicability, but did not decide. |
| Adequacy of Discriminatory Intent Pleading | RPI’s actions were motivated by Zhao’s race/national origin (Chinese), thus discriminatory under Title VII. | No plausible facts suggest adverse actions were due to Zhao’s race or origin. | Insufficient facts; complaint dismissed. |
| Sufficiency of Factual Allegations | Sufficient allegations as a pro se litigant entitle her to a liberal construction of the complaint. | Complaint fails minimum pleading requirements even under pro se standard. | Complaint fails plausibility standard required by law. |
| Motion to Stay Discovery | No specific argument advanced by Zhao. | Stay needed if case survives motion to dismiss. | Denied as moot. |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (sets the plausibility standard for pleading in federal court)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (establishes requirements for a complaint’s factual sufficiency)
- Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53 (2006) (limits Title VII to employment actions)
- Gulino v. N.Y. State Educ. Dep't, 460 F.3d 361 (2d Cir. 2006) (Title VII requires employer-employee relationship)
- Littlejohn v. City of New York, 795 F.3d 297 (2d Cir. 2015) (pleading standards for Title VII discrimination claims)
- Vega v. Hempstead Union Free Sch. Dist., 801 F.3d 72 (2d Cir. 2015) (minimal inference of discriminatory motivation required for Title VII claim)