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The Sixth Circuit Court has overturned previous rulings in favor of Ohio State University (OSU) and professor Giorgio Rizzoni in a case brought by former Ph.D. student Meng Huang, who alleged sexual harassment and retaliation. The court found that key evidence had been improperly excluded from the trial, significantly prejudicing Huang's claims.

 Allegations of Harassment and Retaliation

Huang filed her lawsuit in 2018, accusing Rizzoni, her Ph.D. adviser, of sabotaging her doctoral candidacy after she rejected his romantic advances. She claimed that over three and a half years, Rizzoni subjected her to unwanted physical contact and, after she resisted, manipulated her Ph.D. examination process to ensure her failure. Rizzoni denied these allegations, asserting that Huang’s claims followed criticisms he made about her academic performance.

Improper Evidence Exclusion Leads to Reversal

In a split decision, the Sixth Circuit vacated both the summary judgment granted to OSU and the trial victory for Rizzoni. The court ruled that Huang’s case against OSU should have gone to a jury, as the lower court erred in treating Huang’s roles as a student and employee as mutually exclusive under Title VII. The panel emphasized that a student can also be considered an employee when academic and employment duties overlap.

Additionally, the court found that Huang's retaliation claims were improperly dismissed. The judges stated that Huang’s physical rejection of Rizzoni’s advances constituted enough evidence of opposition, even without formal complaints. The court also criticized the exclusion of critical evidence, such as emails in which Rizzoni appeared to threaten Huang’s academic progress and blocked information about her strong academic record.

OSU Student Harassment reversal : Differing Judicial Opinions

While the majority ruled in favor of a new trial, U.S. Circuit Judge Chad A. Readler partially dissented, arguing that the evidentiary errors were not serious enough to warrant a retrial. He stated that the jury had already heard significant evidence about Rizzoni's conduct and ultimately sided with him, casting doubt on whether the blocked evidence would have changed the outcome.

OSU Student Harassment reversal : Impact and Next Steps

The case now returns to the lower court for further proceedings, with Huang’s legal team preparing to present the previously excluded evidence. Representatives for OSU and Rizzoni declined to comment on the ruling.