Laura Beny v. University of Michigan, et al.

Whether federal courts may apply the judge-made “honest belief” doctrine to grant summary judgment in Title VII cases when: (1) this Court’s unanimous decisions in Desert Palace, Inc. v. Costa, 539 U.S. 90 (2003), and Ames v. Ohio Department of Youth Services, 605 U.S. 303 (2025), require that circumstantial evidence of discrimination reach juries and reject atextual judicial frameworks that distort Title VII’s statutory text; (2) the federal circuits are irreconcilably split, with the Third and D.C. Circuits rejecting the doctrine as violative of jury trial rights while the Sixth and Seventh Circuits apply it broadly to dismiss cases with substantial circumstantial evidence, while the First, Second, Fourth, and Fifth Circuits recognize it in varying degrees, and while still the Ninth Circuit has left it unadopted; and (3) the doctrine operates as a “tautological trap” that automatically credits employer assertions of belief without allowing juries to evaluate credibility, directly contravening Rule 56’s requirement that reasonable inferences favor the non-movant and the U.S. Constitution’s Seventh Amendment provision of the jury-trial right.