6th Circuit unconvinced by transgender professor’s discrimination, retaliation claims

Recently, the U.S. 6th Circuit Court of Appeals (whose rulings apply to all employers in Ohio and Michigan) affirmed a lower court’s award of summary judgment (dismissal without a trial) to Kent State University and its leadership in a case where the professor’s vitriolic tweets supported Kent State’s decision to both deny the professor the ability to teach on main campus and revoke an earlier offer to help develop a new gender-studies major.

Facts

GPat Patterson, a transgender professor at a regional campus of Kent State University (KSU) who uses they/them pronouns, sought to become the new director of KSU’s Center for the Study of Gender and Sexuality in early 2021, despite the fact that the center wasn’t actively operating. In the interim, KSU Dean Mandy Munro-Stasiuk offered to reduce Patterson’s teaching load so they could help develop a new gender-studies major. But Patterson became frustrated by the appointment of Professor Julie Mazzei as chair of the university committees tasked with overseeing both endeavors.

In a four-week long tweetstorm, Patterson attacked both KSU and colleagues. They referred to Munro-Stasiuk and Mazzei as “transphobes” and “cishet white ladies in charge” who were engaged in “f*ckery,” “trans-antagonism,” and “epistemic violence” among other colorful language. Patterson also sent emails to KSU professors voicing the same vitriol and dissatisfaction.