MaClean v. Stuart Weitzman Shoes
2012 U.S. Dist. LEXIS 45940
D.N.J.2012Background
- Plaintiff Allison Maclean alleged NJLAD discrimination based on demotion and discharge from her Atlantic City store.
- Hours were reduced in March 2009, rendering her part-time while Ramos remained full-time; Rendon, a Hispanic manager, made the decision.
- Rendon allegedly stated discriminatory remarks about Plaintiff’s white parents and American birth during a holiday-off request dispute.
- Plaintiff reported a disrespectful incident to a regional manager, Wilkes, who allegedly claimed Rendon wouldn’t have used those words; Plaintiff was terminated the next day.
- Defendant removed the case to federal court and seeks summary judgment on all counts.
- Court applies summary judgment standard and analyzes discrimination and retaliation claims under NJLAD using the McDonnell Douglas framework and related standards.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prima facie case for discriminatory demotion under NJLAD | Maclean argues she was better qualified or background shows majority discrimination | Weitzman argues she fails to show unusual employer discriminating against the majority | Not established; plaintiff failed to show unusual-majority discrimination |
| Termination based on national origin | Termination allegedly influenced by ethnicity/national origin | Termination based on overall business economics and performance, not discrimination | Summary judgment granted for defendant; reasons pretext not shown |
| Retaliatory discharge claim | Plaintiff was terminated for complaints about harassment and holiday-time issues | Termination due to policy violation and alleged false customer complaint | No causal link established; grant of summary judgment for defendant |
Key Cases Cited
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (Supreme Court 1986) (genuine issue of material fact standard for summary judgment)
- Celotex Corp. v. Catrett, 477 U.S. 317 (Supreme Court 1986) (burden on movant to show absence of genuine issue of material fact)
- Fuentes v. Perskie, 32 F.3d 759 (3d Cir. 1994) (pretext standard in discrimination cases)
- Iadimarco v. Runyon, 190 F.3d 151 (3d Cir. 1999) (framework for NJLAD claims parallel to Title VII)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (Supreme Court 1973) (burden-shifting framework for discrimination defenses)
- Ezold v. Wolf, Block, Schorr & Solis-Cohen, 983 F.2d 509 (3d Cir. 1992) (pretext and burden-shifting explained)