Brittany Williams v. Safelite Group, Inc.

Summary

The United States District Court for the District of Maryland denied Safelite Group, Inc.’s motion for summary judgment on Brittany Williams’ Title VII retaliation claim. The court also denied Safelite’s motion for leave to assert allegedly unrelated misappropriation counterclaims and denied Williams’ motion to sever those counterclaims as moot.

Holdings

1. A reasonable juror could find that Williams engaged in protected opposition because she reported sexualized comments about her body and clothing that she reasonably believed constituted sexual harassment.
2. An employment action need not affect the terms and conditions of employment to be materially adverse for purposes of Title VII retaliation; it is sufficient if the action might have dissuaded a reasonable worker from engaging in protected activity. The evidence was sufficient for a reasonable juror to find that Safelite's investigation, reduced performance evaluation, and final written warning met that standard.
3. Williams presented sufficient evidence for a reasonable juror to infer that Safelite's decisionmaker knew of her protected activity and that a causal connection existed between her complaint and the adverse actions.
4. Summary judgment was improper because the evidence would permit a factfinder to conclude that Safelite's stated reasons for disciplining Williams were pretextual.
5. Safelite's proposed misappropriation counterclaims were not compulsory under Federal Rule of Civil Procedure 13(a) because Safelite did not have the claims when the pleadings were served and the alleged misappropriation did not arise from the same transaction or occurrence as Williams's retaliation claim.
6. Leave to amend was properly denied because adding the proposed counterclaims after discovery closed would prejudice Williams, create delay and juror confusion, and was unnecessary because Safelite could pursue the alleged misappropriation in a separate action.

Questions Presented

1. Whether the evidence created a genuine dispute of material fact as to Williams's Title VII retaliation claim.
2. Whether Williams's complaint about sexualized comments constituted protected opposition under Title VII.
3. Whether Safelite's investigation, final written warning, and reduced performance evaluation could constitute materially adverse retaliation.
4. Whether the proposed misappropriation counterclaims were compulsory under Federal Rule of Civil Procedure 13(a).
5. Whether Safelite should receive leave under Federal Rule of Civil Procedure 15(a)(2) to assert the proposed counterclaims after discovery had closed.

Disposition

other