A former Stryker Sales LLC representative may be able to show she was fired for complaining about sex bias despite the 19-month gap between her complaint and discharge, a Philadelphia federal judge ruled.

The temporal proximity between protected job activities and adverse employment actions typically must be close to raise on inference of a causal link, the U.S. District Court for the Eastern District of Pennsylvania said. But causation proof “is very fact-based” and Lindsay Lake has other evidence from which a jury could also connect her protected bias complaint to Stryker’s adverse decision to fire her, the court said. ...

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