Rehm v. Young Mens Christian Association of Greater Waukesha County Inc, 2:21-cv-00237

Background

Plaintiff Katherine Rehm, a long-time YMCA executive, was promoted to Vice President of Operations in 2016 and supervised association-wide functions; a male colleague (Geoff Mertens) held a similar VP role but received higher pay.
Rehm alleged pay disparity, raised the issue with CEO Chris Becker, and received modest raises and year-end bonuses in 2017–2019; she asserts performance remained strong through January 2020.
Rehm informed Becker she was undergoing in‑vitro fertilization (IVF) and later told him she was pregnant after an embryo transfer; Becker had made alleged anti‑pregnancy remarks to staff prior to her termination.
On February 13, 2020 Becker terminated Rehm with vague criticisms (leadership, attendance) without prior warnings; Rehm alleges the reasons were pretextual and tied to her sex/child‑bearing capacity.
Rehm sued under Title VII (including pregnancy discrimination) and the Equal Pay Act; the YMCA moved to partially dismiss Claim Three (Title VII termination for gender/child‑bearing capacity). The court denied that motion and also denied Rehm’s request for attorneys’ fees for opposing the motion.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of Claim Three (Title VII sex/pregnancy discrimination) under Rule 12(b)(6)	Rehm alleged she is a protected person (pregnancy/IVF), was meeting expectations (recent bonuses, approved goals), suffered an adverse action (termination), and Becker made anti‑pregnancy comments and knew of her IVF — supporting causation and pretext.	YMCA argued Rehm failed to plead she was terminated "because of" her sex or childbearing capacity and did not sufficiently connect Becker's comments to her termination.	Court denied partial motion to dismiss: allegations are sufficient at pleading stage to make the claim plausible.
Adequacy of causal/link allegations (timing and comments)	Timing (compliments/bonus in Dec 2019, approved goals Jan 2020, termination Feb 2020) plus Becker's alleged anti‑pregnancy statements and knowledge of IVF support an inference of discriminatory motive.	YMCA said the comments were not shown to be directed at Rehm and no direct causal link was pled.	Court held that at the pleading stage the combination of timing, comments, and knowledge plausibly alleges discrimination; plaintiff need not prove causation yet.
Whether plaintiff pleaded she met employer's legitimate expectations	Rehm pointed to recent bonuses, positive emails, and approved 2020 goals as evidence she met expectations.	YMCA emphasized the stated reasons for termination (leadership, missing meetings) and argued insufficient pleading that those were pretextual.	Court found Rehm alleged sufficient facts to show she was meeting expectations shortly before termination, supporting a prima facie inference of discrimination.
Request for attorneys' fees/sanctions for filing the partial motion to dismiss	Rehm asked fees, calling the defendant’s motion frivolous and lacking recent controlling law.	YMCA defended the motion as a routine, debatable Rule 12(b)(6) filing; sanctions require extraordinary circumstances.	Court denied fee request: advocacy of a debatable pleading motion is not sanctionable absent extraordinary circumstances.

Key Cases Cited

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (pleading standard: must state a plausible claim)
Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (plausibility standard and evaluation of complaints)
Hall v. Nalco Co., 534 F.3d 644 (7th Cir. 2008) (adverse action based on childbearing capacity constitutes sex discrimination)
City of Los Angeles v. Manhart, 435 U.S. 702 (U.S. 1978) (treatment based on childbearing implicates sex discrimination)
Tate v. SCR Med. Transp., 809 F.3d 343 (7th Cir. 2015) (sex‑discrimination allegations need only aver adverse action on basis of sex to survive pleading challenge)
Luevano v. Wal–Mart Stores, Inc., 722 F.3d 1014 (7th Cir. 2013) (pleading standards for discrimination claims)
Coleman v. Donahoe, 667 F.3d 835 (7th Cir. 2012) (pretext standard: identify inconsistencies or implausibilities in employer’s explanation)
Abrego v. Wilkie, 907 F.3d 1004 (7th Cir. 2018) (Title VII prohibits discrimination based on sex)