Background
Debra Pratt, a human resources manager at Wisconsin Aluminum Foundry, reported multiple instances of sexual harassment, sex discrimination, and race discrimination to her supervisor. After reporting these issues, she received a poor performance review and was subsequently fired. The district court granted summary judgment for the employer on all claims, concluding Pratt failed to establish a prima facie case and had not engaged in protected activity.
The court’s reasoning
The Seventh Circuit held that the district court erred by weighing evidence and resolving credibility disputes at the summary judgment stage. The court found sufficient evidence of sex discrimination based on a discriminatory culture, dishonest justifications for termination, and comparators who were treated more favorably. The court also ruled that Pratt engaged in protected activity by reporting conduct she reasonably believed was unlawful, rejecting the district court’s heightened standard for HR employees.
What it means going forward
The case is remanded for trial on the sex discrimination and retaliation claims, allowing a jury to determine if the employer’s stated reasons for firing Pratt were pretextual.