Pryor v. Seyfarth, Shaw, Fairweather & Geraldson

Donna F. Pryor (plaintiff) worked as a secretary for the law firm Seyfarth, Shaw, Fairweather & Geraldson (defendant), which specialized in employment law. For nine years, the lawyers to whom Pryor was assigned gave her consistently good performance reviews, and one of the lawyers, Dalinka, went out of his way to compliment Pryor's work. Pryor complained to the firm that another lawyer, Woodford, sexually discriminated against her in violation of Title VII of the Civil Rights Act of 1964. Shortly thereafter, the firm's personnel manager observed Pryor taking time out to work on a visiting friend's fingernails. The manager fired Pryor without prior warning. Pryor sued the firm for violating Title VII and for retaliatory discharge. The firm's pretrial pleadings established a prima facie nondiscriminatory defense for its actions: (1) Pryor was discharged for poor performance and inappropriate attire rather than for the fingernail incident or in retaliation for Pryor's Title VII complaint, (2) Dalinka inflated Pryor's performance reviews, and (3) Pryor ignored the firm's instructions for all secretaries to take Excel software training. Pryor responded that the firm's defense was pretextual because: (1) the fingernail incident occurred during her break; (2) the firm did not order Excel training, but nevertheless she voluntarily enrolled for that training; and (3) her discharge must have been retaliatory, because otherwise the fingernail incident would have resulted only in a warning. The federal trial court granted the firm's motion for summary judgment. Pryor appealed to the United States Court of Appeals for the Seventh Circuit, which initially determined that summary judgment was proper as to Pryor's Title VII claim.