Bentley v. AutoZoners, LLC, 935 F.3d 76

Rachel Bentley worked part-time at AutoZone's Wallingford, CT store from April 2013 until termination on September 17, 2014; the store lacked a permanent manager for much of that period.
Bentley alleges co-worker/PSM Manny Valentin repeatedly made sexist, derogatory comments about women; Bentley and two other employees (including PSM Justine Case) were fired after an August–September 2014 investigation into multiple workplace incidents.
Bentley admitted in a signed September 2014 statement that she directed an extremely crude remark at Valentin months earlier; she also made a signed August 2014 statement describing Valentin’s sexist comments but answered “No” when asked whether she had reported those comments.
Bentley testified at deposition that she had reported Valentin’s sexist remarks to HR (Nuno Antunes) before August 2014, but that testimony conflicted with contemporaneous texts, her signed statements, and other filings.
AutoZone’s handbook prohibited harassment and abusive language and directed employees to report misconduct to supervisors or HR; PSMs could direct day-to-day tasks but lacked authority to hire, fire, set pay, or set schedules (tangible employment actions required higher-level authorization).
The district court granted summary judgment to AutoZone on claims under the Connecticut Fair Employment Practices Act (discriminatory discharge, retaliatory discharge, hostile work environment); Bentley appealed and the Second Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Discriminatory discharge (sex)	Termination was pretext; firing for a single crude remark inconsistent with pattern of tolerance for Valentin’s sexist comments	AutoZone fired for legitimate nondiscriminatory reason (Bentley’s crude language and policy violation)	Affirmed: AutoZone’s reason legitimate; Bentley failed to show pretext
Retaliatory discharge	Termination was retaliation for reporting Valentin’s harassment; temporal proximity supports inference	No evidence AutoZone knew of reports before Aug 2014; temporal proximity alone insufficient to show pretext	Affirmed: temporal proximity + disputed notice insufficient to show pretext
Vicarious liability for hostile work environment (was Valentin a "supervisor"?)	Valentin exercised control over daily work and wore PSM uniform; thus AutoZone strictly liable	Under Vance, supervisor status requires authority to take tangible employment actions (hire, fire, reassign with economic consequences) which Valentin lacked	Affirmed: Valentin not a supervisor because he lacked authority to effect tangible employment actions
Employer negligence for hostile work environment (notice/remedy)	AutoZone had notice of long-standing sexist comments and failed to remediate	Bentley’s deposition claiming earlier notice is contradicted by her prior signed/written statements and other records	Affirmed: deposition testimony was unequivocally contradicted; no triable issue on employer notice

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for discrimination claims)
Vance v. Ball State Univ., 570 U.S. 421 (supervisor status requires power to take tangible employment actions)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (plaintiff may prove pretext via same evidence as prima facie case)
Summa v. Hofstra Univ., 708 F.3d 115 (employer liability for coworker-created hostile work environment depends on notice/negligence)
Raspardo v. Carlone, 770 F.3d 97 (hostile work environment standard: severe or pervasive conduct)
Jeffreys v. City of New York, 426 F.3d 549 (courts may discount contradictory plaintiff testimony in rare circumstances)
Fosamax Prods. Liab. Litig., 707 F.3d 189 (sham affidavit/testimony doctrine applied at summary judgment)
Stalter v. Wal-Mart Stores, Inc., 195 F.3d 285 (illustrative discussion of employer discipline proportionality)
Burlington Indus., Inc. v. Ellerth, 524 U.S. 742 (definition of tangible employment actions and vicarious liability)