Donley v. Stryker Sales Corp., 906 F.3d 635

Donley, a Stryker employee demoted from corporate-accounts director to clinical manager, filed an internal complaint in June 2014 alleging a sales manager had sexually harassed another employee; that manager was investigated and fired (with severance).
About six weeks after Donley filed the complaint, Stryker opened an investigation into Donley based on photographs she had taken of a vendor CEO in an intoxicated state at a company meeting in Vail and shared with coworkers.
Disputed timeline: Donley says her supervisor Thompson saw the photos the night of the incident; Thompson later testified he learned of them from other employees; HR director Ferschweiler testified she first learned of the incident during an August exit interview but Thompson testified he told Ferschweiler earlier.
Stryker terminated Donley for "inappropriate conduct and poor judgment" citing violation of company policy; she was not offered severance; Donley sued under Title VII § 2000e-3 for retaliation.
District court granted summary judgment to Stryker, finding no causal link between Donley’s protected complaint and her firing; the Seventh Circuit reversed and remanded, finding genuine disputes of material fact about motive and timing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Donley established a triable issue that her termination was retaliatory (causation/pretext)	Suspicious timing (investigation started soon after complaint); inconsistent explanations from Thompson and Ferschweiler; employer’s shifting accounts and EEOC position show pretext	Termination resulted from Donley’s independent misconduct in Vail; decision-makers lacked retaliatory knowledge at the relevant time	Reversed: factual disputes (timing, inconsistencies, HR involvement) could allow a reasonable jury to infer retaliation; summary judgment inappropriate
Whether comparator (fired sales manager who received severance) supports inference of retaliation	Manager was treated more favorably despite misconduct, suggesting discriminatory/retaliatory motive	Manager and Donley were not similarly situated (different rank, supervisors, standards, and circumstances)	Comparator evidence insufficient on current record to defeat summary judgment because the employees were too dissimilar

Ortiz v. Werner Enterprises, Inc., 834 F.3d 760 (7th Cir. 2016) (summary-judgment standard in employment cases)
Chaib v. Geo Group, Inc., 819 F.3d 337 (7th Cir. 2016) (view facts in plaintiff's favor on summary judgment)
McCoy v. WGN Cont'l Broadcasting Co., 957 F.2d 368 (7th Cir. 1992) (remarks on differing positions in administrative proceedings)
Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 133 (2000) (pretext and jury inference of discriminatory motive)
Castro v. DeVry University, Inc., 786 F.3d 559 (7th Cir. 2015) (pretext by showing inconsistencies in employer’s explanation)
Coleman v. Donahoe, 667 F.3d 835 (7th Cir. 2012) (reversing summary judgment for employer where factual disputes existed)
Boumehdi v. Plastag Holdings, LLC, 489 F.3d 781 (7th Cir. 2007) (circumstantial evidence and pretext analysis)
Gordon v. United Airlines, Inc., 246 F.3d 878 (7th Cir. 2001) (contradictions supporting inference of unlawful motive)
Matthews v. Waukesha County, 759 F.3d 821 (7th Cir. 2014) (input from a biased decisionmaker can render employer liable)
Greengrass v. Int'l Monetary Systems, Ltd., 776 F.3d 481 (7th Cir. 2015) (comparative-treatment evidence as circumstantial proof of unlawful motive)
Gates v. Caterpillar, Inc., 513 F.3d 680 (7th Cir. 2008) (requirements for a valid comparator)