Candolfi v. Alterra Group, 272 A.3d 829

Candolfi was hired as Allterra’s remote Marketing Director in 2018, announced her pregnancy on Jan 14, 2019, and received modest raises/bonuses during employment.
On Feb 8, 2019 Candolfi received a one‑year Employee Review rating several categories "Some Improvement Needed," and was instructed to work from the office until performance improved.
Candolfi refused to sign the review without an addendum clarifying whether the in‑office requirement was temporary; Allterra later terminated her employment.
Candolfi sued for wrongful discharge/pregnancy discrimination; after discovery Allterra moved for summary judgment and the court converted the trial date to a motions hearing.
Candolfi’s counsel missed the May 20, 2021 hearing (having filed an unsuccessful continuance request); the court found counsel in direct civil contempt and ordered payment of $2,467.50 to defense counsel as a sanction/purge.
The trial court refused to consider Candolfi’s untimely opposition and unsigned affidavit, granted Allterra summary judgment on the merits, and entered the contempt order against counsel; on appeal the court affirmed summary judgment and reversed the contempt order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court properly denied Candolfi’s untimely motion/opposition	West/Candolfi argued the court should construe the rules to favor fairness and consider the late filings	Allterra argued the response was untimely under Md. Rule 2‑311(b) and the court could decline to consider it	Denial of consideration was within the court’s discretion and not an abuse; refusal to consider untimely opposition affirmed
Whether summary judgment for Allterra was proper on pregnancy discrimination claim	Candolfi argued timing of pregnancy announcement and firing, bonuses, subjective performance ratings, and circumstantial mosaic evidence created a triable issue	Allterra proffered legitimate nondiscriminatory reasons (documented performance issues, insubordination, refusal to comply with in‑office directive)	Court applied McDonnell Douglas burden‑shifting; even assuming a prima facie case, Candolfi failed to produce substantial evidence of pretext; summary judgment affirmed
Whether direct civil contempt order against Candolfi’s counsel was proper	Candolfi/West challenged the contempt order and sanction as improper and his appealability	Allterra argued counsel’s failure to appear warranted summary contempt and sanction	Finding of contempt was permissible, but the order improperly punished past conduct and used a sanction identical to the purge provision; contempt order reversed

McDonnell Douglas v. Green, 411 U.S. 792 (established burden‑shifting framework in employment discrimination cases)
Texas Dep’t of Cmty. Affs. v. Burdine, 450 U.S. 248 (plaintiff must show employer’s reasons are pretextual)
State v. Roll & Scholl, 267 Md. 714 (civil contempt is coercive and requires a purge provision)
Breona C. v. Rodney D., 253 Md. App. 67 (sanction must be distinct from purge; purge must allow exoneration)
Kowalcyzk v. Bresler, 231 Md. App. 203 (discussion of lawful purge provisions in civil contempt)
Makovi v. Sherwin‑Williams Co., 316 Md. 603 (Maryland wrongful discharge in violation of public policy—pregnancy discrimination context)
Molesworth v. Brandon, 341 Md. 621 (example of direct evidence of discrimination vs. circumstantial proof)
Muse‑Ariyoh v. Bd. of Educ., 235 Md. App. 221 (standard for opposing summary judgment; nonmoving party must present admissible evidence)