The U.S. Court of Appeals for the Sixth Circuit affirmed summary judgment against Carlotta Collins in her employment discrimination lawsuit against the City of Detroit and two supervisors from the Detroit Water and Sewerage Department. The decision, filed Jan. 14, 2026, upholds the lower court's ruling dismissing Collins' claims of race and sex discrimination, retaliation, and hostile work environment.
Collins, who worked for the City of Detroit since 2002, initially started as a junior clerk in the Income Tax Division before transferring to the Detroit Water and Sewerage Department. At the time of her termination, she was employed as a level three customer-service specialist in DWSD's Finance Division.
The case centers on Collins' allegations that her supervisors, Mihai Facaeanu and Carlos Vazquez, discriminated against her based on her race and sex. Facaeanu served as the manager of the Finance Division where Collins worked. Collins also claimed her supervisors retaliated against her for complaining about the alleged discrimination and created a hostile work environment.
The legal proceedings took a significant turn when Collins was terminated from her position while her discrimination lawsuit was still pending. This development prompted Collins to amend her complaint to include additional claims of retaliation and a violation of Michigan's Whistleblower Protection Act.
The Michigan Whistleblower Protection Act provides legal protections for employees who report violations of law or regulation by their employers. By adding this claim, Collins argued that her termination was in retaliation for her protected activities under state law, in addition to her federal discrimination claims.
The case proceeded through the U.S. District Court for the Eastern District of Michigan, where defendants successfully moved for summary judgment. Summary judgment is granted when there are no genuine disputes of material fact and the moving party is entitled to judgment as a matter of law. The district court's decision to grant summary judgment indicated that Collins failed to present sufficient evidence to support her discrimination and retaliation claims.
On appeal to the Sixth Circuit, Collins challenged the district court's summary judgment ruling. The three-judge panel, consisting of Circuit Judges Cole, Mathis, and Hermandorfer, reviewed the case with Circuit Judge Mathis writing the opinion. The appeals court's affirmation of the lower court's decision represents a complete victory for the defendants.
The Sixth Circuit's opinion was marked "not recommended for publication," which means it will not serve as binding precedent for future cases. This designation is typically used for cases that apply established legal principles to specific facts without creating new legal standards or addressing novel legal questions.
Employment discrimination cases like Collins' typically involve claims under Title VII of the Civil Rights Act of 1964, which prohibits workplace discrimination based on race, color, religion, sex, or national origin. To succeed on such claims, plaintiffs must generally establish that they belong to a protected class, suffered an adverse employment action, and that the action was motivated by discriminatory intent.
Retaliation claims require plaintiffs to show they engaged in protected activity, such as filing a discrimination complaint, that they suffered an adverse employment action, and that there was a causal connection between the protected activity and the adverse action. The timing of Collins' termination during her pending lawsuit could have supported her retaliation claims, but the courts ultimately found insufficient evidence to support her allegations.
The case highlights the challenges employees face in proving discrimination and retaliation claims in employment litigation. Even when termination occurs during pending discrimination litigation, courts require substantial evidence of discriminatory or retaliatory motives rather than relying solely on suspicious timing.
For municipal employers like the City of Detroit, the decision reinforces the importance of proper documentation and legitimate business reasons for employment actions. The successful defense against Collins' claims suggests the defendants were able to articulate non-discriminatory reasons for the actions Collins challenged.
The affirmation also validates the district court's analysis of the evidence and legal standards applied to Collins' claims. Federal appeals courts review summary judgment decisions de novo, meaning they apply the same legal standards as the trial court without deference to the lower court's conclusions.
While this decision concludes Collins' federal court litigation, it represents one outcome in the ongoing landscape of employment discrimination law. The case serves as a reminder that successful discrimination claims require more than allegations of unfair treatment and must be supported by evidence sufficient to create genuine disputes of material fact for trial.
The Sixth Circuit's decision affects employment practices and litigation in Michigan, Ohio, Kentucky, and Tennessee, the states within the circuit's jurisdiction. Municipal employees and employers in these jurisdictions can look to this case as an example of how courts evaluate discrimination and retaliation claims in the public sector employment context.