Hochstadt v. Worcester Foundation for Experimental Biology

In 1971, the Worcester Foundation for Experimental Biology (the foundation) (defendant) offered Dr. Harvey Ozer and Ozer’s wife, Dr. Joy Hochstadt (plaintiff), positions as senior scientists. The foundation set Ozer’s salary at $24,000 and Hochstadt’s salary at $18,000. Ozer and Hochstadt accepted their offers, but Hochstadt subsequently claimed that her salary was discriminatory and sought more money. The foundation agreed to adjust Hochstadt’s and Ozer’s salaries so that each received $21,000. In January of 1972, Hochstadt began attending regular policy-and-planning meetings with a small group of the foundation’s cell biologists. Hochstadt used the meetings to share personal complaints about the foundation, foundation leadership, and her salary. Hochstadt’s complaints were disruptive and eventually caused the group to stop meeting. Hochstadt subsequently filed formal charges against the foundation with state and federal agencies including the Equal Employment Opportunity Commission, alleging that the foundation had discriminated against her by giving her a lower starting salary than a male scientist. Hochstadt also filed a class-action complaint with the Department of Health, Education, and Welfare on behalf of the foundation’s female employees and sued the foundation under Title VII of the Civil Rights Act of 1964 (Title VII). Hochstadt settled her Title VII claim with the foundation in December of 1974. Hochstadt then tried to obtain salary information from other foundation employees, but her efforts interfered with scientists’ ongoing research and upset the staff. Hochstadt also started rumors that the foundation was going to lose its federal funding for failing to comply with affirmative-action regulations, invited an outside scientist to conduct a secret affirmative-action survey at the foundation, and gave the foundation’s confidential salary information to a journalist. The foundation fired Hochstadt in mid-1975, and Hochstadt sought a preliminary injunction requiring the foundation to revoke its termination decision. Hochstadt claimed that she had been terminated in retaliation for challenging the foundation’s unlawful employment practices, in violation of § 704(a) of Title VII. The district court denied Hochstadt’s request for injunctive relief, and she appealed.