Lane v. Lift 1428, LLC, 1:16-cv-00087

Christen Lane, hired Jan 12, 2015 as Lift 1428’s senior sales/marketing hire with $90,000 base + 5% commission; role involved lead generation and direct sales reporting to CEO David McDonald.
Lane disclosed her pregnancy to McDonald on May 11, 2015 and discussed leave/return plans with HR on June 11, 2015.
On June 24, 2015 Lane and co-worker Chasen Thomas were placed on identical performance-improvement plans (Q3 revenue goal $150,000); Lane’s plan also altered her commission structure.
Nineteen days into the three-month plan (July 20, 2015) Lift terminated Lane, citing poor sales performance; Thomas was not terminated and was given the full plan period and later stayed until 2016.
Lane sued under the Tennessee Human Rights Act alleging pregnancy discrimination; Lift moved for summary judgment which the court denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Prima facie nexus between pregnancy and termination	Lane: termination 70 days after pregnancy notice + immediate adverse changes (monitoring, PIP) supports causal nexus	Lift: 70-day gap too long to show temporal proximity; no nexus	Denied — 70 days plus contemporaneous adverse actions (PIP, changed duties/monitoring) sufficient for jury inference of nexus
Comparator / disparate treatment	Lane: Thomas is a proper comparator — same small sales team, same supervisor, identical PIP but treated differently	Lift: Thomas not comparable (less experience, different duties, sales history, pay)	Denied — factual disputes permit jury to find they were similarly situated and Lane was treated worse (fired after 19 days vs. Thomas given full term)
Employer’s stated reason (poor sales) is legitimate	Lane: Lift’s proffered reason is pretextual given disparate treatment and timing	Lift: Non-discriminatory reason — lack of sales justifies termination	Denied — Lift’s reason is legitimate but evidence of disparate treatment and timing permits inference of pretext for jury
Mitigation of damages	Lane: she did some networking and later sought work; caregiving limited formal job search	Lift: Lane failed to actively seek work after Nov 2015	Denied — material factual disputes over reasonableness/extent of mitigation efforts preclude summary judgment

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes burden-shifting framework for circumstantial discrimination)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (standard for viewing evidence on summary judgment)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (standard for judging sufficiency of evidence at summary judgment)
Cline v. Catholic Diocese of Toledo, 206 F.3d 651 (pregnancy discrimination treated as sex discrimination)
Ercegovich v. Goodyear Tire & Rubber Co., 154 F.3d 344 (standard for similarly situated comparator analysis)
Frizzell v. Southwest Motor Freight, 154 F.3d 641 (pretext examples and burden-shifting guidance)
Asmo v. Keane, 471 F.3d 588 (temporal proximity can support causal inference)
Singfield v. Akron Metropolitan Housing Authority, 389 F.3d 555 (less-than-three-month proximity sufficient for inference of retaliation)