Ezold v. Wolf, Block, Schorr & Solis-Cohen

Nancy Ezold (plaintiff) was hired by Wolf, Block, Schorr and Solis-Cohen (Wolf) as a partnership-track associate. The litigation-department chairman told Ezold it would not be easy for her at Wolf because she was a woman and had not attended an Ivy League law school or been on law review. At first, Ezold received only small, uncomplicated cases. Although Ezold received positive evaluations, there were concerns about her legal analytical ability starting early in her tenure. Of the eight partnership candidates in Ezold’s class, five males and one female were admitted to the partnership. Ezold was not promoted and resigned. Ezold sued Wolf for sex discrimination in violation of Title VII of the Civil Rights Act of 1964 (Title VII). Wolf maintained Ezold was rejected for partnership because her legal analytical ability did not meet the firm’s partnership standard. Arguing that Wolf’s proffered reason was pretextual, Ezold presented evidence to show she was as qualified as similarly situated males who were promoted to partner. The district court held that Wolf’s articulated reason for rejecting Ezold was a pretext for discrimination. The court compared Ezold’s evaluations to those of eight males who had been promoted and found the evaluations were the same or inferior to Ezold’s. On appeal, Wolf argued that the evidence did not support the district court’s finding of pretext.