DESANTO v. IKEA NORTH AMERICAN SERVICES, LLC, 2:21-cv-01533

DeSanto, an HR Recruitment Delivery Manager hired in 2017, took FMLA paternity leave beginning May 11, 2020; his mid‑year review shortly before leave was positive and he had no prior discipline.
While DeSanto was on leave, his direct supervisor Eleanor Tattar was placed on involuntary leave and later left IKEA; DeSanto learned of the situation and sought clarification before returning.
On July 31, 2020 outside counsel interviewed DeSanto as part of an internal investigation; he reported that colleague Richard Carsley had engaged in age‑ and gender‑discriminatory conduct and had previously raised those concerns with Tattar.
DeSanto returned to work on August 11, 2020 and was terminated on August 17, 2020; post‑termination paperwork cited disrespectful behavior, a disfavored management style, and an "unsustainable working dynamic."
DeSanto sued alleging retaliation under Title VII and the ADEA and FMLA claims; IKEA moved to dismiss the Title VII and ADEA retaliation counts for failure to plead sufficient facts.
The court denied IKEA’s partial motion to dismiss Counts I (Title VII retaliation) and II (ADEA retaliation), finding DeSanto plausibly alleged protected activity and a causal connection based on temporal proximity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Title VII retaliation: whether DeSanto pleaded protected activity and causation	DeSanto says he engaged in protected opposition by reporting Carsley's age/sex discrimination to his supervisor and outside counsel; termination followed 17 days later	IKEA argues allegations are conclusory, fail to specify discriminatory acts or timing, and do not show causal link to termination	Court: Denied dismissal — allegations of specific complaints about gender discrimination and 17‑day gap are plausibly suggestive of causation at pleading stage
ADEA retaliation: whether complaint sufficiently pleaded opposition to age discrimination and causation	DeSanto alleges he specifically complained of age discrimination to supervisor and outside counsel; termination soon after supports inference	IKEA argues lack of particulars about alleged ageist conduct and no causal nexus	Court: Denied dismissal — plaintiff specifically mentioned age discrimination and temporal proximity permits an inference of causation
Pleading‑stage standard: whether plaintiff must plead a prima facie case	DeSanto contends he need not plead a prima facie case at pleading stage; need only allege facts making claim plausible	IKEA effectively treats prima facie elements as required at pleadings	Court: Confirms that a prima facie case is not required at motion to dismiss; plausibility under Iqbal/Twombly governs

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (complaint must plead factual content making claim plausible)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for pleadings)
Santiago v. Warminster Twp., 629 F.3d 121 (3d Cir. 2010) (three‑part Iqbal analysis for Rule 12(b)(6))
Malleus v. George, 641 F.3d 560 (3d Cir. 2011) (articulating stepwise pleading review)
Fowler v. UPMC Shadyside, 578 F.3d 203 (3d Cir. 2009) (plaintiff must ‘show’ entitlement to relief with facts)
LeBoon v. Lancaster Jewish Cmty. Ctr. Ass’n, 503 F.3d 217 (3d Cir. 2007) (short temporal proximity may be unusually suggestive of causation)
Connelly v. Lane Constr. Corp., 809 F.3d 780 (3d Cir. 2016) (plausibility and reasonable expectation that discovery will reveal necessary proof)
Barber v. CSX Distrib. Servs., 68 F.3d 694 (3d Cir. 1995) (complaints to management qualify as protected activity)
Kachmar v. SunGard Data Sys., Inc., 109 F.3d 173 (3d Cir. 1997) (temporal proximity as evidence of retaliation)
Farrell v. Planters Lifesavers Co., 206 F.3d 271 (3d Cir. 2000) (methods for inferring causation including timing and ongoing antagonism)