Where there were disputed issues of material fact over whether a woman suffered disparate treatment and unequal pay because of her sex, the trial court wrongly granted the defendants’ motion for summary judgment.
Background
Colette Cunningham appeals the district court‘s order granting summary judgment to the Loudoun County Sheriff’s Office on her disparate-treatment and pay-discrimination claims under Title VII.
Disparate treatment
“To establish a prima facie case of disparate treatment, a plaintiff must prove four elements: (1) membership in a protected class; (2) satisfactory job performance; (3) adverse employment action; and (4) different treatment from similarly situated employees outside the protected class.” The district court concluded that plaintiff failed to meet her burden on the third and fourth elements.
Plaintiff alleges that the Sheriff’s Office denied her a promotion along with the attendant schedule, forced her to remain a duty officer, and deprived her of additional administrative support while she performed the day-to-day duties of station commander. Each of these actions constitute adverse employment actions based on the facts of this case.
As a result of those decisions, plaintiff worked a grueling schedule rife with overtime hours. And this new paradigm significantly altered the conditions of her employment. Therefore, the district court erred in concluding that the defendants were entitled to summary judgment on the adverse-employment-action...
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