Peck v. United Parcel Service, Inc., 4:22-cv-00381

Heidi H. Peck worked for UPS from 2004 until her termination in December 2021, rising to Business Manager.
Peck was terminated after two internal investigations found misreporting of “service failures” at centers she managed; she was accused of either directing or passively allowing the misreporting after being instructed to correct it.
Peck had a previously unblemished employment record but was implicated by witness statements during the investigations.
Peck did not receive her annual Manager Incentive Program (MIP) bonus following her termination, as she was not employed through year-end and was not recommended for the bonus.
After her termination, she engaged in UPS’s Employee Dispute Resolution (EDR) process, which produced a nonbinding recommendation for her reinstatement; UPS offered her a demoted role instead, which she declined.
Peck sued UPS for gender discrimination, unpaid wages under the Idaho Wage Claims Act, breach of contract (regarding the MIP bonus and EDR process), and breach of implied covenant of good faith and fair dealing. Both parties moved for summary judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Gender discrimination under Title VII/IHRA	Peck was terminated for alleged conduct not punished in similarly-situated male managers	UPS terminated Peck for legitimate, nondiscriminatory reasons and comparators were not similarly situated	No discrimination; summary judgment for UPS
Unpaid MIP bonus under Idaho Wage Claims Act	Bonus was earned and due at termination	Bonus was not due because Peck wasn’t employed at year-end nor recommended	Bonus was not due; summary judgment for UPS
Breach of contract re: MIP bonus and EDR process	Termination to avoid bonus and refusal to follow EDR breached contract	As an at-will employee, no contract right to bonus or to enforce EDR recommendation	No breach; summary judgment for UPS
Breach of implied covenant of good faith and fair dealing	UPS acted in bad faith by withholding bonus and EDR	No express or implied term was breached	No breach; summary judgment for UPS

Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting in discrimination cases)
Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 133 (pretext and summary judgment in discrimination cases)
Ricci v. DeStefano, 557 U.S. 557 (types of discrimination claims under Title VII)
Cornwell v. Electra Cent. Credit Union, 439 F.3d 1018 (standards for Title VII disparate treatment)
Villiarimo v. Aloha Island Air, Inc., 281 F.3d 1054 (disparate treatment and pretext)
Hawn v. Exec. Jet Mgmt., Inc., 615 F.3d 1151 (comparator analysis in discrimination claims)
Vasquez v. County of Los Angeles, 349 F.3d 634 (similarly situated employee analysis)