Conti v. American Axle and Manufacturing, Inc.

Suzanne Conti (plaintiff) was hired by American Axle & Manufacturing, Inc. (AAM) (defendant) in 1997 as a commodity manager. In 2003, Conti was promoted to codirector of AAM’s strategic-sourcing division. She joined codirector Larry Earhart, who had been the sole director since 2001. When Conti was promoted, she was placed in a lower salary band than Earhart was placed in upon his 2001 promotion. However, at Conti’s promotion, Earhart was moved to a lower salary band. Just six months after Conti’s promotion, Conti and Earhart were transferred. Conti moved to the new-model-launch division, where she worked under the division’s director, Mike Pannucci. Although Conti retained her codirector salary, the new position was lower in rank. When Pannucci later vacated the director position, Conti was promoted to the role. However, she was titled a manager, not a director, and earned less money than Pannucci. Conti sued AAM, alleging sex discrimination under Michigan’s Elliott-Larsen Civil Rights Act (ELCRA) and wage discrimination under the federal Equal Pay Act. In support of her ELCRA claim, Conti’s complaint pointed to her career history plus publications from AAM’s CEO praising gender-biased management, a 2001 statement by Earhart saying Conti was not promoted because she was female, and a supervisor’s statements not to hire women who were mothers or overweight. AAM moved for summary judgment, arguing that any differential treatment was based on differences in qualifications and performance. AAM described Conti’s management style as abrasive and ineffectual. Concerning differences in pay, AAM argued that Conti often earned a higher salary than her male counterparts. The district court granted summary judgment in AAM’s favor. Conti appealed.