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Chadwick v. WellPoint, Inc.
United States Court of Appeals for the First Circuit
561 F.3d 38 (2009)
Laurie Chadwick (plaintiff) worked for WellPoint, Inc. (defendant). Chadwick had four children under the age of 12 and was attending a class at the University of Southern Maine. Chadwick’s husband was the primary caretaker of the children while Chadwick worked. Chadwick had been in her position at WellPoint for seven years. In 2005, Chadwick received an excellent performance review. Chadwick’s supervisor encouraged her to apply for an open management position. In fact, Chadwick was already doing much of the work required of the manager position. Chadwick interviewed for the position, but WellPoint offered the promotion to Donna Ouelette. Ouelette had been in the same position as Chadwick, although she had only been in that position for about one year. Ouelette scored lower on her 2005 performance review than did Chadwick. After Chadwick did not receive the promotion, the hiring supervisor told Chadwick, “It was nothing you did or didn’t do. It was just that you’re going to school, you have the kids and you just have a lot on your plate right now.” The hiring supervisor also stated that if the other interviewees were in Chadwick’s position, they would feel overwhelmed. Chadwick sued WellPoint for sex-based discrimination, claiming that WellPoint hired Ouelette because of the stereotype that mothers of young children neglect their work in favor of their family responsibilities. The district court granted WellPoint summary judgment. Chadwick appealed.
Rule of Law
Holding and Reasoning (Stahl, J.)
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