Martinez-Burgos v. Guayama Corp.
2011 U.S. App. LEXIS 17836
| 1st Cir. | 2011Background
- Martinez worked as a temporary Fill & Pack Operator at Baxter’s Guayama, Puerto Rico plant via Kelly Services, starting September 2003.
- She received training on SOPs and GMPs; she was repeatedly reprimanded for gum, jewelry, eye protection, and tardiness, and received formal Employee Counseling Reports.
- In February 2005 Baxter created five full-time Fill & Pack Operator openings; Martinez applied but did not rank in the top five after interviewing against a four-member panel.
- Martinez was seven months pregnant at the time of applying; she began maternity leave March 15, 2005 and gave birth March 26, 2005; KS paid maternity benefits until about May 10, 2005.
- She was not rehired for the full-time position or for a temporary assignment after her leave, and she later obtained other work through KS.
- Martinez alleged two Title VII pregnancy discrimination claims: failure to hire for the full-time role and failure to rehire after maternity leave; the district court granted summary judgment for Baxter on these claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prima facie case for failure to hire? | Martinez contends she was pregnant and qualified but not chosen. | Baxter asserts Martinez was not qualified and did not meet top interview scores. | Martinez failed to prove qualification; Baxter had a valid non-discriminatory hiring basis. |
| Prima facie case for failure to rehire after maternity leave? | Martinez argues pregnancy led Baxter to not renew after leave. | Baxter cites non-discriminatory reasons and better performance by a replacement worker. | Martinez did not show pretext; Baxter's reasons were credible, so summary judgment affirmed. |
Key Cases Cited
- Smith v. F.W. Morse & Co., 76 F.3d 413 (1st Cir. 1996) (mandates no discharge based on pregnancy as a category; legitimate reasons may prevail)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. Supreme Court 1973) (establishes burden-shifting framework for discrimination claims)
- Rathbun v. AutoZone, Inc., 361 F.3d 62 (1st Cir. 2004) (prima facie showing not onerous; need for similarly situated comparator)
- Greenberg v. Union Camp Corp., 48 F.3d 22 (1st Cir. 1995) (prima facie burden is easily met; supportive standards for discrimination cases)
- Kosereis v. Rhode Island, 331 F.3d 207 (1st Cir. 2003) (describes burden of proving pretext after legitimate reasons are provided)
- Alvarado-Santos v. Dep’t of Health, 619 F.3d 126 (1st Cir. 2010) (comparing qualifications and non-discriminatory justification in hiring decisions)
- Santiago-Ramos v. Centennial P.R. Wireless Corp., 217 F.3d 46 (1st Cir. 2000) (pretext framework for evaluating employer’s asserted reasons)
- Cumpiano v. Banco Santander P.R., 902 F.2d 148 (1st Cir. 1990) (prima facie showing creates a rebuttable presumption of discrimination)
- Texas v. Lesage, 528 U.S. 18 (U.S. Supreme Court 1999) (observes limits on discrimination claims where evidence shows weaker records than successful applicants)