The plan promised 30 days to improve - Brown gave her 25
She came back from medical leave on a Monday. By Tuesday, she had a new performance improvement plan on her desk.
A former associate director at Brown University's medical school has filed a federal lawsuit alleging the Ivy League institution discriminated against her based on disability, race, and national origin - and retaliated after she took protected medical leave and pushed for better pay for Black women on campus.
The complaint, filed October 19, 2026, in the US District Court for the District of Rhode Island, names Brown as the sole defendant across ten counts under federal and state employment laws, including the Americans with Disabilities Act (ADA), the Family and Medical Leave Act (FMLA), and Title VII of the Civil Rights Act.
From "exceptional" to improvement plan
The worker joined Brown in August 2019 as assistant director in the Office of Diversity and Multicultural Affairs, part of the university's Division of Biology and Medicine. According to the complaint, she ran programming, managed recruitment partnerships, handled budgets, and supported medical students and faculty. Her 2022 performance review rated her "Exceptional." In March 2021, Brown gave her an Administrative Award. She had never received a single disciplinary warning.
That track record shifted after a 2022 restructure. Brown folded her office into a new entity and promoted her to associate director, bumping her salary from $75,000 to $90,000. But the filing alleges the new role came with operational responsibility across two centers, no structured onboarding, and a new reporting line.
The pay equity push
The worker is described in the complaint as a participant in Black Women @ Brown, an affinity group that raised concerns about Black women receiving lower pay and titles than white counterparts while shouldering heavier workloads. After a university compensation review in late 2022, she wrote to Brown's vice presidents requesting a further equity assessment, arguing her responsibilities had grown beyond what the earlier review covered.
According to the complaint, her new supervisor questioned why she had not disclosed her involvement in the group. The filing further alleges the supervisor made comments about tensions between Haitians and Dominicans, stating in substance that the groups "do not get along" - a remark the complaint says the worker found demeaning given her national origin.
The complaint alleges scrutiny ramped up from there. In May 2023 - roughly four years in with no prior discipline - Brown issued its first performance improvement plan. The filing states the PIP reached back to meetings from the previous year's transition period and recast them as performance counseling, though the worker alleges she was never told those meetings served that purpose.
She challenged it. According to the complaint, Brown's HR reviewed the matter, stripped the PIP of its disciplinary nature and timeline, and converted it into an expectations memo. But scheduled follow-up meetings with senior leadership were then cancelled without explanation, the filing states, leaving her concerns unresolved.
Medical leave - and the interview that triggered a recall
The complaint alleges the worker was treated for adjustment disorder, a condition that affected her ability to think clearly, interact with others, and manage daily self-care. She took approved FMLA leave in June 2023 for about twelve weeks, and a second approved leave starting in March 2024.
During that second leave, the filing states, she applied for an internal director-level role in the Office of the Provost - after confirming with HR that she could interview while on medical leave. Brown put her through multiple rounds, including a full-day final interview on campus on May 14, 2024.
Then the story turned. According to the complaint, HR questioned how she could attend an interview while unable to perform her regular job - and told her that showing up meant she was fit to return. Brown required her back immediately, the filing alleges, despite medical documentation indicating she still needed leave.
She returned on May 20, 2024, the complaint states, to remain employed and to avoid jeopardizing the position she had interviewed for. The very next day, a former supervisor - who, according to the filing, had not directly managed her for roughly eight months - sat down with the current supervisor and HR and presented a second PIP.
Twenty-five days from return to termination
The second PIP targeted her job knowledge, reliability, accountability, and communication. But the complaint alleges every criticism was based on events from before her medical leave - not on anything she had done since walking back through the door.
The plan promised a 30-day evaluation window through June 21, 2024, with a final employment decision around July 5. The worker submitted the required deliverables by the June 7 deadline, the filing states.
Seven days later, on June 14, Brown terminated her. That was one week before the stated evaluation period ended and three weeks before the promised decision date.
According to the complaint, the worker had also written to Brown's president on May 22, raising concerns that the PIP misrepresented her performance and could hurt her shot at the internal role. She learned the following day that she had not been selected.
A pattern of differential treatment, the complaint alleges
The filing describes what it frames as a broader pattern. Another colleague, the complaint states, received social recognition from the supervisor, was allowed remote work flexibility and to bring her child to the office, and was publicly welcomed back after absences. The worker's return from extended medical leave, by contrast, allegedly went unacknowledged.
When both the worker and a male colleague were selected for an outside health-equity opportunity, the supervisor allegedly congratulated only the male colleague - until he pointed out the worker had been selected too. The worker was then told she could not participate, the filing alleges, while her colleague was permitted to go ahead.
What's at stake
The complaint seeks compensatory, liquidated, and punitive damages, along with attorneys' fees, back pay, front pay or reinstatement, and injunctive relief. A jury trial has been demanded.
For HR teams, the case throws a spotlight on the mechanics of performance improvement plans around medical leave - particularly the exposure when a PIP lands the day an employee returns, draws entirely on pre-leave conduct, and gets cut short before its own stated timeline runs out.
The allegations in the complaint have not been tested, and no court has made any findings on the claims.
