Law School Case Brief
Chadwick v. WellPoint, Inc. - 561 F.3d 38 (1st Cir. 2009)
Summary judgment is granted where there is no genuine issue as to any material fact and the movant is entitled to judgment as a matter of law. Fed. R. Civ. P. 56(c). An issue is genuine if the evidence is such that a reasonable jury could return a verdict for the nonmoving party.
Laurie Chadwick brought a claim of sex discrimination under Title VII, 42 U.S.C. §§ 2000e et seq., against WellPoint, Inc. and Anthem Health Plans of Maine, Inc. (collectively, WellPoint), after she was denied a promotion. She alleged that her employer failed to promote her because of a sex-based stereotype that women who are mothers, particularly of young children, neglect their jobs in favor of their presumed childcare responsibilities. The district court granted summary judgment to WellPoint because a decisionmaker did not explicitly say that Chadwick’s sex was the basis for her assumption that the employee would not be able to handle the demands of work and home.. Chadwick appealed.
Did the district court err in granting summary judgment in favor of WellPoint?
Reversing as to summary judgment, the court determined that the district court erred in granting summary judgment in favor of WellPoint. To support her claim, Chadwick --the mother of six-year-old triplets and an older child--pointed to the fact that she was significantly more qualified for the promotion than was the woman who received the job, and also highlighted three statements made by management around the time of the promotion decision. The court ruled that the district court's critique was not an adequate basis upon which to grant summary judgment. A jury could reasonably determine that a sex-based stereotype was behind the decisionmaker's explanation. Chadwick was entitled to her day in court. As to the second issue presented on appeal, the court held that the district court did not abuse its discretion by excluding the expert testimony proffered by Chadwick.
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