Simpson v. Vanderbilt University

The plaintiff-appellant was a professor at the Vanderbilt University School of Medicine who solicited clients for her own private business, which the defendant, Vanderbilt University, considered to be a violation of its Conflict of Interest Policy, its By-Laws, and its Participation Agreement. The defendant terminated the plaintiff’s employment and she sued the defendant, alleging that her termination was due to gender discrimination in violation of Title VII of the Civil Rights Act and the Tennessee Human Rights Act. The district court granted summary judgment in favor of the defendant, holding that the plaintiff failed to identify a suitable male comparator and thus did not establish a prima facie case of discrimination. The Sixth Circuit affirmed, finding key differences between the plaintiff’s conduct and that of the male comparator she identified, including most notably the fact that the male comparator had disclosed his work outside of Vanderbilt University on his conflict of interest form.