Wei Jiang v. Duke University

── Wei Jiang v. Duke University ── Court: Court of Appeals for the Fourth Circuit Date: June 05, 2026 Category: General USCA4 Appeal: 25-1184 Doc: 64 Filed: 06/05/2026 Pg: 1 of 15 UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 25-1184 WEI JIANG, M.D., Plaintiff – Appellant, v. DUKE UNIVERSITY; DUKE UNIVERSITY HEALTH SYSTEMS, INCORPORATED; MOIRA RYNN, M.D., in her individual and official capacity; MARY E. KLOTMAN, in her individual and official capacity, Defendants – Appellees. Appeal from the United States District Court for the Middle District of North Carolina, at Greensboro. Loretta C. Biggs, Senior District Judge. (1:22-cv-00101-LCB-JEP) Submitted: January 7, 2026 Decided: June 5, 2026 Before AGEE, THACKER, and QUATTLEBAUM, Circuit Judges. Affirmed by unpublished per curiam opinion. ON BRIEF: Valerie L. Bateman, NEW SOUTH LAW FIRM, Carrboro, North Carolina, for Appellant. Harrison M. Gates, Durham, North Carolina, Amie Flowers Carmack, MORNINGSTAR LAW GROUP, Raleigh, North Carolina, for Appellees. Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 25-1184 Doc: 64 Filed: 06/05/2026 Pg: 2 of 15 PER CURIAM: Dr. Wei Jiang appeals the district court’s Rule 12(b)(6) dismissal of her complaint, contending that the court required too much of her pleadings and erred in concluding that she failed to allege sufficient facts to support her claims of race, national origin/color, sex, and age discrimination and retaliation against her employer and supervisors. Having reviewed the complaint and Dr. Jiang’s proposed amended complaint, we discern no error and affirm the district court’s judgment. I. Dr. Jiang has spent most of her professional career at Duke University. 1 2 Originally employed as research associate in 1989, she was eventually awarded tenure as a full professor in 2014. Throughout her career, Dr. Jiang has collaborated with colleagues in China, taking trips and attending or presenting at conferences there while also visiting her family. For about five years of her clinical research, Dr. Jiang worked as the “[p]rincipal (but not sole) [i]nvestigator,” J.A. 16, on a study about “the effects of the drug escitalopram on patients with myocardial ischemia,” known as the REMIT study (“Responses of Myocardial Ischemia to Escitalopram Treatment”), J.A 9–10. Following that study, Dr. 1 Dr. Jiang’s joint employers are defendants Duke University and Duke University Health Systems. Because we see no meaningful difference in the allegations or claims against them here, we refer to the two collectively as “Duke University.” 2 Because we are reviewing the district court’s grant of a Rule 12(b)(6) motion to dismiss, we draw the facts from Dr. Jiang’s complaint. See Feminist Majority Found. v. Hurley, 911 F.3d 674, 680 (4th Cir. 2018) (“Because the district court dismissed the Complaint pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure, we accept and recite the alleged facts in the light most favorable to the plaintiff[].”). 2 USCA4 Appeal: 25-1184 Doc: 64 Filed: 06/05/2026 Pg: 3 of 15 Jiang and her cohorts published six papers in various medical journals, including a 2013 paper published in the Journal of the American Medical Association (JAMA). Dr. Jiang