(CN) – A Maine mother of four can proceed with her claim that her employer denied her a promotion based on the stereotype that mothers of young children can’t fulfill their job responsibilities, the 1st Circuit ruled.
Laurie Chadwick sued Wellpoint Inc. and Anthem Health Plans of Maine after she was denied a promotion to the “Recovery Specialist Team Lead” position. She brought her lawsuit under Title VII of the Civil Rights Act, which prohibits sex-based discrimination.
At the time, Chadwick had an 11-year-old son and 6-year-old triplets. When supervisor Nanci Miller told Chadwick she would not be getting the promotion, she explained, “It was nothing you did or didn’t do. It was just that you’re going to school (one class per semester), you have the kids, and you just have a lot of your plate right now.”
The district court granted summary judgment to Wellpoint because of the lack of evidence that Chadwick did not get the job because she is a woman.
However, Judge Stahl of the Boston-based federal appeals court ruled that Chadwick presented enough evidence to warrant a trial, and that a specific discussion of her gender was not necessary.
“Presumably, the district court was looking for Miller to say explicitly that she thought Chadwick would be overwhelmed because she is a woman with kids,” Stahl wrote.
“To require such an explicit reference,” the judge continued, “would make it exceedingly difficult to prove most sex discrimination cases today.”
Stahl remanded the case to the district court for further proceedings.