Background
Debra Pratt, an HR manager at Wisconsin Aluminum Foundry, reported multiple instances of sexual harassment, racial discrimination, and retaliation by supervisors. After reporting these issues, she received a low performance review and was fired one week after complaining about retaliation. The district court granted summary judgment for the employer on all claims.
The court’s reasoning
The Seventh Circuit held that the district court erred in granting summary judgment on the sex discrimination and retaliation claims. The court found that Pratt presented sufficient evidence of a discriminatory culture, including sexist comments by managers and differential treatment compared to male counterparts who received similar negative feedback but were not fired. The court also ruled that Pratt engaged in protected activity by reporting harassment and that the timing of her termination supported a causal link to her complaints. The court affirmed summary judgment only on the pay discrimination claim due to a lack of a sufficiently close comparator.
What it means going forward
The decision reinforces that employers cannot use summary judgment to resolve disputes over credibility in discrimination cases where evidence of a hostile culture and pretextual reasons exists. It clarifies that HR employees are entitled to the same retaliation protections as other employees when reporting violations.