Kathleen Williams v. Wells Fargo Bank
658 F. App'x 76
| 3rd Cir. | 2016Background
- Kathleen Williams, age 54 and a Wells Fargo teller since 1983, was terminated in December 2012 after an internal investigation found she accessed her sister’s Wells Fargo accounts 27 times between August and November 2012.
- Wells Fargo’s Code of Ethics prohibited accessing customer information without a business purpose; management concluded Williams’s repeated accesses were unjustified and violated teller procedures (no referrals entered).
- Williams contends she accessed the accounts with her sister’s knowledge/consent to explore trust/product options and that two younger tellers were hired in anticipation of her termination.
- Wells Fargo produced evidence that the two younger tellers were hired earlier to fill separate vacancies and that Williams’s actual replacement was a 54‑year‑old employee.
- Williams sued under the ADEA for age discrimination; the District Court granted summary judgment for Wells Fargo, and Williams appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Williams established a prima facie ADEA case by showing she was replaced by a sufficiently younger person | Williams: two younger tellers (ages 29 and 31) were hired immediately prior to her firing, creating an inference of age discrimination | Wells Fargo: hiring records show those tellers were hired earlier to fill other vacancies; Williams was replaced by a coequal-aged hire | Court: Williams failed to show she was replaced by a sufficiently younger person; no prima facie showing |
| Whether Wells Fargo’s stated reason (Code of Ethics violation) was pretext for discrimination | Williams: she had her sister’s consent so firing was pretextual | Wells Fargo: termination was for violating internal procedures and accessing accounts without business purpose | Court: even assuming prima facie case, Williams didn’t show employer’s reason was pretextual; summary judgment proper |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (framework for burden‑shifting in discrimination cases)
- Smith v. City of Allentown, 589 F.3d 684 (3d Cir. 2009) (elements of prima facie ADEA case)
- Jones v. United Parcel Serv., 214 F.3d 402 (3d Cir. 2000) (nonmoving party must present evidence beyond unsupported allegations to defeat summary judgment)
- Fireman’s Ins. Co. v. DuFresne, 676 F.2d 965 (3d Cir. 1982) (bare assertions insufficient to avoid summary judgment)
- Kautz v. Met‑Pro Corp., 412 F.3d 463 (3d Cir. 2005) (evidence required to show employer’s reason is pretextual)
- Gardner v. State Farm Fire & Cas. Co., 544 F.3d 553 (3d Cir. 2008) (appellate standard of review for summary judgment)
- Scott v. Harris, 550 U.S. 372 (summary judgment evidence viewed in light most favorable to nonmoving party)
- Keller v. Orix Credit Alliance, Inc., 130 F.3d 1101 (3d Cir. 1997) (discussing McDonnell Douglas framework)