Appeals Court Rejects Grad Student's Discrimination Suit in Michigan

Black Issues in Higher Education, Dec 23, 1999

ANN ARBOR, Mich. -- The state Court of Appeals has refused to reinstate a racial discrimination suit by a former graduate student who claimed the University of Michigan rejected his dissertation and denied him a doctorate because he is Black.

In a unanimous decision, the three-judge panel found no factual basis for claims Philip Emeagwali filed against the university and individual faculty members.

In 1987, Michigan accepted Emeagwali as a pre-candidate for its civil engineering doctoral program that included a fellowship that covered tuition and provided him with a monthly stipend, court records show.

Between then and 1991, he completed 35 graduate credits and won a 1989 prize for significant achievements in the application of supercomputers to scientific and engineering problems.

After he twice failed his qualifying exams in civil engineering, he applied for a joint doctoral program in civil engineering and scientific computing. The university agreed to let him submit his dissertation for review to determine whether it deserved a doctorate. The dissertation failed.

He then sued for racial discrimination and for breach of a contract to award him a doctorate. The case was dismissed without trial.

The appeals court upheld that decision, saying Emeagwali failed to show he was treated differently from other graduate students who twice failed their civil engineering qualifying exam.

In addition, the court says that "there was no evidence in the record that any of the defendants had a predisposition to discriminate against African Americans or, even assuming such predispositions existed, that the defendants acted on them."

It also found no evidence that White students received supercomputer access when Emeagwali didn't, that the actions of any defendant "derived from racial animus" or that "White students received more extensive or better-quality faculty feedback concerning their dissertations."

In addition, it rejected the claim he had received unfavorable grades on his coursework and qualifying exams in retaliation for filing discrimination complaints.

Julie Peterson, Michigan's director of news and information services, says she couldn't discuss details of the case because it involves an individual student's academic record but that no further appeal has been filed.