Huang v. Ohio State University
What’s at stake: Whether a key federal employment law protects students workers from discrimination
Summary: Meng Huang, a former PhD student at the Ohio State University, filed a lawsuit alleging a shocking pattern of abuse: Her advisor had sexually harassed her for years, starting the first time they met. For three and a half years, her lawsuit alleged, her advisor, a tenured professor at OSU’s College of Engineering, had used his power and influence to coerce her to meet with him alone and subject her to unwanted touching–and, ultimately, to punishment when she rebuffed his advances.
Like many graduate students, Huang held research positions that guaranteed her tuition and provided stipends. She was first a “Graduate Fellow” and then a “Graduate Research Assistant.” Ohio State classified the former role as an academic position and the second as a job. But the two positions were nearly identical, and Huang was paid for her work in both. Her lawsuit explained that as a student employee, she dealt with constant harassment and the ongoing threat that her advisor could expel her from the program, rescind her pay, and, ultimately, cause her to lose her visa.
In 2018, Huang sued Ohio State and her advisor for sex discrimination and retaliation. The lawsuit includes claims under both education and employment laws. Huang lost at the trial court and appealed to the Sixth Circuit. There, Public Justice filed an amicus brief and presented oral argument, addressing one of the primary issues in the case: whether Meng was an employee protected by the employment law Title VII, rather than only a student. In August 2024, the Sixth Circuit ruled in her favor, holding that a graduate student can be both a student and an employee at the same time, regardless of title.
Core legal question: The district court granted summary judgment to Ohio State on Huang’s Title VII claims on the basis that, in its view, she was only a student and not an employee protected by Title VII when she was a Graduate Fellow–her role when she was sexually harassed. In its brief and at argument, Public Justice explained that graduate students may be students and employees simultaneously, regardless of their title, and courts should holistically assess graduate students’ work using the ordinary common law agency test to see whether they are employees. The Sixth Circuit unanimously agreed, and reversed the district court opinion.
