A U.S. District Court judge has denied an employer’s motion for summary judgment, finding that the reason for given for termination could be pretext for pregnancy discrimination.

United States District Court, District of Massachusetts

SUMMARY: (court decision – opens in PDF)

“Plaintiff Christin Ronzio brings a pregnancy discrimination suit against Defendant Williams Lea, Inc. (‘Williams Lea’) for terminating her employment on the basis of her pregnancy in violation of Mass. Gen. Laws c. 151B, §4. …

“Plaintiff has produced evidence to support her prima facie case: she was pregnant, performed her job at an acceptable level, and her employment was terminated while male peers were retained. In turn, Defendant provided a legitimate, nondiscriminatory reason for termination. It states it needed to eliminate her position to reduce costs due to financial challenges exacerbated by COVID-19. A reasonable juror could find that the reason given for her termination was a pretext based on three factors.

“First is the temporal proximity of Plaintiff’s pregnancy disclosure and her termination. … Plaintiff notified Defendant of her pregnancy on March 26, 2020 and was terminated on April 24, 2020. Although Defendant insists the decision maker, Ms. Denise Reid, learned of Plaintiff’s pregnancy after the decision to terminate was already made, the timing is a fact question.

“Second, Defendant’s alleged timeline for decision-making has shifted during the litigation. In its answer to Plaintiff’s discrimination charge before the Massachusetts Commission Against Discrimination, Defendant stated that terminations were the result of cost-cutting measures arising out of the COVID-19 pandemic. In this suit, in contrast, Defendant alleges that discussions to terminate Plaintiff began in December 2019 and that her ultimate termination was the end-result of a prolonged plan that pre-dated the pregnancy. Defendant lacks any documentation that demonstrates a final decision to terminate Plaintiff prior to the pregnancy. “Third, the parties dispute whether Ms. Reid’s choice of comparator masks pretext. …

“Defendant claims Ms. Reid, Plaintiff’s supervisor, compared Plaintiff to Mr. Scott Incognito as the comparator because he shared the same title, sector focus, and region as Plaintiff. Defendant claims Plaintiff was terminated because Mr. Incognito had the better performance record. Plaintiff argues pretext because Mr. Incognito was not the appropriate comparator given his much longer tenure at Williams Lea. Instead, Plaintiff identifies Mr. Griffin Maloney, hired around the same time as Plaintiff, as the appropriate comparator; he was not terminated despite having made fewer sales than Plaintiff. Defendant points out Mr. Maloney had a different sector focus.

“After viewing the facts in the light most favorable to the Plaintiff, based on these three factors, the Court finds a material fact dispute remains for the cause of the termination.