Bentley v. AutoZoners, LLC

From April 2013 to September 2014, Rachel Bentley (plaintiff) worked as a sales associate at a store owned by AutoZoners, LLC (AutoZone) (defendant). The store had no store manager. AutoZone’s district manager David Campanile visited periodically. He also arranged for the manager of a nearby location to visit weekly and organize the employees’ work schedules. For day-to-day management, Campanile relied on two of the store’s parts sales managers (PSMs). The PSMs were responsible for opening and closing, assigning tasks between employees, and imposing informal discipline. PSMs were not authorized to hire, fire, promote, demote, or formally discipline employees. From January 2014 onward, the PSMs were Justine Case and Manny Valentin. Bentley and Valentin did not get along. Both were fired in September 2014 for inappropriate conduct. Bentley sued AutoZone, asserting claims under the Connecticut Fair Employment Practices Act, including a hostile-work-environment claim. Bentley alleged Valentin made over 20 disparaging comments about women beginning in January 2014. During her deposition, Bentley originally claimed that she reported each occurrence to human-resources manager Nuno Antunes by text as it occurred. However, she recanted that statement when Antunes’s text records revealed no such texts. Evidence showed that Case reported discord between Bentley and Valentin to Campanile in late July 2014. Antunes met with Case, who said Valentin frequently disparaged women. On August 14, Antunes met with Bentley, who agreed that Valentin frequently disparaged women. Bentley signed a written statement stating that she had not previously reported Valentin’s conduct. Valentin told Antunes he never made derogatory statements. He also claimed that Bentley had directed a crude remark to him, something Bentley did not deny. The district court granted summary judgment in AutoZone’s favor. Regarding the hostile-work-environment claim, the court concluded AutoZone was not liable because Valentin’s conduct could not be imputed to AutoZone. Bentley appealed.