The U.S. Court of Appeals for the Sixth Circuit affirmed a lower court's ruling in favor of the University of Toledo in an employment discrimination case brought by former Human Resources director Wendy Davis. The appeals court rejected Davis's claims that she was fired due to racial discrimination and retaliation for speaking out about racial issues in the workplace.
Circuit Judge Nalbandian, writing for the three-judge panel that included Judges Kethledge and Bush, found that the university had legitimate performance-based reasons for terminating Davis from her position as Associate Vice President of Human Resources and Talent Development.
Davis, who is Black, worked in the University of Toledo's Human Resources Department for five years before her termination. She initially served as Director of Human Resources for Academic Administration and Student Services before being promoted to Interim Associate Vice President of Human Resources and Talent Development. The university later removed her interim status, making the position permanent.
According to the court opinion, Davis "took the helm of a troubled Human Resources Department" where she "clashed with her supervisor and fell short of expectations in several areas." The university ultimately fired Davis citing job performance issues, but Davis contested this reasoning in federal court.
Davis alleged that the University of Toledo "spun up a pretext" to terminate her employment because of her race and to retaliate against her for addressing racial concerns in the workplace. She brought her claims under federal employment discrimination laws, seeking relief for what she characterized as unlawful termination.
The case initially proceeded in the U.S. District Court for the Northern District of Ohio, where the university sought summary judgment to dismiss Davis's claims. The district court agreed with the university's position and granted summary judgment, finding that Davis had not established sufficient evidence to support her discrimination and retaliation claims.
Dissatisfied with the district court's ruling, Davis appealed to the Sixth Circuit Court of Appeals, which has jurisdiction over federal appeals from Ohio, Michigan, Kentucky, and Tennessee. The case was assigned to a three-judge panel for review.
In affirming the lower court's decision, the Sixth Circuit found that the evidence supported the university's contention that Davis was terminated for legitimate, non-discriminatory reasons related to her job performance. The court noted that Davis had experienced conflicts with supervisors and had failed to meet expectations in multiple areas of her responsibilities.
The appeals court's opinion suggests that while Davis viewed her termination through the lens of racial discrimination and retaliation, the evidence did not support her interpretation of events. Instead, the court found that the University of Toledo had articulated legitimate business reasons for the employment decision.
The case represents another instance where federal courts have applied stringent standards in evaluating employment discrimination claims. Under federal law, employees alleging discrimination must typically establish that similarly situated employees of different races were treated more favorably, or present other evidence suggesting that race was a motivating factor in the adverse employment action.
For retaliation claims, employees must generally show that they engaged in protected activity, suffered an adverse employment action, and that there was a causal connection between the protected activity and the adverse action. The Sixth Circuit's affirmance suggests that Davis was unable to establish these elements sufficiently to survive summary judgment.
The University of Toledo, a public research university in Ohio, has faced various employment-related legal challenges over the years. Like many large institutional employers, universities must navigate complex employment law requirements while making personnel decisions based on legitimate operational needs.
The ruling provides the University of Toledo with a complete victory in the litigation, as the appeals court's affirmance of summary judgment means Davis's claims have been definitively rejected. The decision also reinforces the principle that employers who can articulate legitimate, non-discriminatory reasons for employment decisions are likely to prevail in discrimination litigation, provided those reasons are supported by evidence.
The case was filed as Case No. 25-3296 in the Sixth Circuit and was decided on Jan. 22, 2026. The court designated the opinion as "not recommended for publication," which means it will not serve as binding precedent for future cases, though it may still be cited as persuasive authority.
Davis has not indicated whether she plans to seek further review of the decision through a petition for rehearing or an appeal to the Supreme Court. Such appeals are discretionary and face significant procedural hurdles, making further review unlikely unless the case presents novel legal issues or conflicts with other circuit court decisions.