A jury will soon decide whether leaders at Duke University accused a researcher of misconduct in retaliation for her reporting sexual harassment at the institution.
U.S. Magistrate Judge Patrick Auld ruled Brahmajothi Mulugu provided enough evidence to show the timing of Duke’s misconduct investigation against her may have been retaliatory, allowing Mulugu’s legal challenge to proceed. In his Jan. 16 decision, Auld denied a motion by Duke to end the lawsuit, concluding a jury should weigh whether Mulugu’s sexual harassment report fueled the university’s misconduct actions against the scientist.
Mulugu, an immunologist in Duke’s Department of Pharmacology and Cancer Biology, sued the university in 2023, alleging leaders conducted an “unjustified” research misconduct investigation after she reported sexual harassment by then-professor Mohamed Bahie Abou-Donia. The university’s Office of Institutional Equity (OIE) substantiated Mulugu’s harassment report in November 2020, and Abou-Donia resigned, according to a case summary in Auld’s decision.
Mulugu left the university in November 2021 after Duke determined she engaged in research misconduct and terminated the grant paying for her employment. The findings led to the retractions of three papers coauthored by Mulugu and Abou-Donia in Military Medicine.
Duke representatives and attorneys for the university did not return messages seeking comment.
In court documents, attorneys for Duke argued Mulugu couldn’t prove a link between the harassment report and the misconduct investigation because the university began investigating Mulugu’s research practices before she reported the harassment, according to Duke’s brief in support of its motion for summary judgment. The evidence demonstrated “Duke officials appropriately investigated serious concerns about Plaintiff’s research practices.” Mulugu’s employment ended as a result of “serious concerns established about her scientific integrity,” Duke’s attorneys wrote in the brief.
Mulugu, who is representing herself in the case, did not return messages seeking comment.
Abou-Donia, a scientist at Duke for nearly 50 years, died on March 26, 2023, eight months before Mulugu filed her claim. We wrote about the three retracted papers Mulugu coauthored with Abou-Donia in 2021 when Duke was investigating the potential misconduct. Abou-Donia had three additional retractions to papers after he resigned, according to our count. We also covered an expression of concern in one of his papers in 2024.
Mulugu is one of six authors on a 2013 paper in Pediatric Research linked to the high-profile misconduct case of former Duke researcher Erin Potts-Kant. The paper was retracted in 2019, two years after the journal became aware of issues with the article. Potts-Kant was accused in a 2015 whistleblower lawsuit of using fake data to collect millions of dollars in federal grants, leading to a $112.5 million settlement in 2019 between Duke and the government. Over the last decade, Duke’s mishandling of several misconduct cases has led to significant sanctions and requirements for the university and its researchers.
Mulugu worked as a research scientist at Duke for more than 25 years in various departments, joining Abou-Donia’s lab in July 2016, according to her complaint.
From the start, Mulugu claimed she was treated unequally by Duke staff regarding lab space and supplies, but she and Abou-Donia had a “mostly cordial working relationship” when she first started, according to her lawsuit.
In May 2018, Mulugu was awarded a grant from the U.S. Department of Defense for a research proposal she submitted. To be principal investigator and start the Institutional Review Board protocol, however, she was required to be an assistant research professor, according to her complaint. Over the next year, Mulugu repeatedly asked Abou-Donia and other Duke administrators for a promotion to assistant research professor, but they did not promote her, according to court records.
Mulugu alleges Abou-Donia indicated the department chair “hated” her. She claims Abou-Donia told her the chair had asked Abou-Donia to “come up with some reason to accuse” Mulugu so she could “be fired,” and the grant given to Abou-Donia, according to Mulugu’s lawsuit. Another Duke administrator allegedly told Mulugu during a discussion that she was “dispensible,” according to her complaint.
Starting in October 2019, Mulugu alleges Abou-Donia began sexually harassing her on a frequent basis, including making explicit comments about her body parts and vulgar statements about being “aroused” when seeing her, according to her complaint. While working late on Dec. 7, 2019, she claims Abou-Donia forced her to touch his penis and prevented her from leaving the room.
“I was fearful of pushing him away as he was an older man,” Mulugu wrote in her complaint. “He blocked the door to stop me from getting out. Thus, he assaulted me.”
As the frequency of the harassment increased, Mulugu started recording her interactions with Abou-Donia, according to court documents.
Mulugu told several faculty members about the harassment shortly after it started and allegedly received mixed guidance, with some colleagues telling her to go to OIE and others warning her of negative professional consequences if she reported the behavior. On Feb. 10, 2020, Mulugu had a meeting with OIE and shared “a glimpse of what was happening,” but she initially asked the office to keep the information on file and not start a formal investigation for fear of retaliation, according to her complaint.
On Feb. 28, 2020, Mulugu informed the chair of the pharmacology and cancer biology department of the alleged sexual harassment, according to deposition testimony cited in Auld’s decision. On March 9, 2020, the department chair told Mulugu she was under an “internal investigation” and administrators confiscated her laptop to allegedly review her data management practices, according to the summary in Auld’s decision.
Duke attorneys claim concerns about Mulugu’s data practices arose before the harassment report. They allege a research quality control officer emailed the department chair on Feb. 26, 2020, regarding Mulugu’s data management practices. In July 2020, an initial Duke assessment concluded a formal research misconduct inquiry was “not warranted at this time,” according to Judge Auld’s summary. In legal briefs, Duke conceded the inquiry was not warranted “because of the inadequacy of the available research record,” according to Auld’s decision.
In November 2020, OIE concluded that Mulugu’s harassment claims were valid, and Abou-Donia resigned. In February 2021, the university resumed the misconduct investigation, determining an inquiry was warranted. Duke ultimately found Mulugu responsible for research misconduct. Specifically, the university found she “could not provide evidence of the source of key data underlying her grant application and three publications,” according to Duke’s summary judgement brief. Duke administrators terminated Mulugu’s grant, which ended her employment in November 2021. It’s unclear whether Duke reported its findings to the Department of Defense.
Military Medicine retracted Mulugu’s three papers in 2022. Retraction notices stated “the institution determined there is insufficient source documentation to verify either the reliability of the published results or the origins of the samples used.”
In allowing Mulugu’s lawsuit to proceed, Auld emphasized that Duke’s “apparent about-face” over the propriety of the research conduct inquiry came after the OIE investigation corroborated Mulugu’s sexual harassment report.
“Defendants evidently would have the Court accept as irrefutable facts both (A) that Defendant Duke University could not proceed with a research misconduct investigation against Plaintiff because she could not produce her data and (B) that Defendant Duke University could resume a research misconduct investigation against Plaintiff (and ultimately find her guilty of research misconduct) because she could not produce her data,” Auld wrote in his ruling.
He dismissed Mulugu’s other claims for race discrimination and fraud, but allowed her retaliation claim to continue. The case is scheduled for trial in June.
Researchers have sued their former institutions in the past to challenge misconduct findings. In 2023, behavioral scientist Francesca Gino sued Harvard University over allegations of misconduct involving her work. In 2022, breast cancer researcher Stacy Blain sued SUNY Downstate in Brooklyn for sex discrimination and retaliation after an investigation determined she committed research misconduct.
In 2025, Sonia Melo, a biochemist and former postdoc at The University of Texas MD Anderson Cancer Center in Houston sued the institution to dispute research misconduct findings. And cancer researcher Jasti Rao sued the University of Illinois College of Medicine at Peoria in 2014 for wrongful termination after the university found in 2013 he manipulated research. Rao, who lost the case in 2018, recently made his debut on the Retraction Watch Leaderboard with 35 retractions.
Like Retraction Watch? You can make a tax-deductible contribution to support our work, follow us on X or Bluesky, like us on Facebook, follow us on LinkedIn, add us to your RSS reader, or subscribe to our daily digest. If you find a retraction that’s not in our database, you can let us know here. For comments or feedback, email us at [email protected].
She is first author on a 2013 net-yet-retracted paper with signs of image manipulation flagged on PubPeer: https://pubpeer.com/publications/967E07925EDAD80B63B5024B91696E