Donley v. Stryker Sales Corp.

Dist. Ct. erred in granting defendant-employer’s motion for summary judgment in plaintiff-employee’s Title VII action alleging that she was terminated in retaliation for reporting that sales manager committed sexual harassment against another co-worker. While Dist. Ct. based ruling on its belief that applicable decision-maker was unaware of plaintiff’s complaint, record in light most favorable to plaintiff showed that defendant’s human resources director was aware of said complaint and played role in supplying information to decision-maker regarding plaintiff’s termination. Moreover, defendant’s explanation that plaintiff was terminated for taking improper photographs of another individual may not have actually motivated decision to discharge plaintiff, where: (1) decision-maker could have initially found that plaintiff’s misconduct was tolerable prior to plaintiff’s report of sexual harassment; and (2) decision-maker and/or individual having role in termination decision only decided to use photograph incident as excuse for termination after plaintiff had made harassment complaint.