Kow-Ching Chang v. Mississippi State University

Summary

This order addresses Mississippi State University’s motion for summary judgment in a pro se Title VII national-origin discrimination and retaliation action brought by Kow-Ching Chang. The court discusses Eleventh Amendment immunity, the McDonnell Douglas framework, and evidence concerning the university’s restrictions on Chang’s supervisory authority and removal as director of a laboratory. The provided text ends before the court’s final disposition of the motion.

Holdings

1. MSU was entitled to summary judgment because the record strongly supported its legitimate, nondiscriminatory reason for disciplining Chang—credible reports of serious supervisory misconduct—and Chang failed to show that the reason was pretextual.
2. MSU was entitled to summary judgment on Chang's retaliation claim because the alleged fourteen- to fifteen-month interval between his protected activity and the adverse employment actions was insufficient, standing alone, to establish the required causal inference, and Chang independently failed to show that MSU's misconduct-based explanation was pretextual.
3. The court stated that Chang could not pursue a procedural due process claim under § 1983 against MSU because Eleventh Amendment immunity barred such claims against the university as an arm of the State of Mississippi.

Questions Presented

1. Whether MSU was entitled to summary judgment on Chang's Title VII national-origin discrimination claim.
2. Whether MSU was entitled to summary judgment on Chang's Title VII retaliation claim.
3. Whether the summary-judgment record showed that MSU's stated reasons for limiting Chang's supervisory authority and removing him as director were pretexts for discrimination or retaliation.
4. Whether the timing of the alleged protected activity and adverse employment actions supported a prima facie retaliation claim.

Disposition

other