Rehm v. Young Mens Christian Association of Greater Waukesha County Inc
2:21-cv-00237
E.D. Wis.Dec 26, 2024Background
- Katherine Rehm, the plaintiff, worked as a Vice President of Operations at the YMCA of Greater Waukesha County (YMCA-GWC), alongside a male colleague, Geoff Mertens, who held a similar VP position focused on branch operations.
- Rehm alleged pay discrimination based on gender, wrongful termination due to her gender and intent to pursue pregnancy, and retaliation, under Title VII and the Equal Pay Act (EPA).
- Rehm raised concerns about being paid less than Mertens; she received a raise after bringing this up, but disparities persisted.
- Rehm underwent IVF treatment in 2019–2020 and claimed the CEO, Chris Becker, made pregnancy-related remarks that suggested discriminatory animus.
- YMCA-GWC terminated Rehm in February 2020, citing performance issues; Rehm argued these reasons were pretextual and manufactured.
- On summary judgment, Rehm waived most claims except for her Title VII claims for unequal pay and wrongful termination. The court granted summary judgment to the defendant on the pay claim but denied it as to wrongful termination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Title VII: Pay Discrimination | Rehm and Mertens held similar roles and responsibilities; pay gap unexplained | Mertens had different, more demanding job duties and qualifications | For Defendant: No sufficient comparator evidence, claim dismissed |
| Title VII: Wrongful Termination (Gender/Pregnancy) | Termination motivated by animus to gender/child-bearing potential; CEO made discriminatory remarks | Termination based on documented performance issues; no discrimination | For Plaintiff: Genuine factual disputes; claim survives summary judgment |
Key Cases Cited
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (guides summary judgment standards)
- Celotex Corp. v. Catrett, 477 U.S. 317 (summarizes burden of proof at summary judgment)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes burden-shifting in discrimination cases)
- Ortiz v. Werner Enterprises, Inc., 834 F.3d 760 (requires looking at totality of the evidence in discrimination cases)
- Hall v. Nalco Co., 534 F.3d 644 (adverse employment action based on childbearing capacity is cognizable under Title VII)
- Emmel v. Coca-Cola Bottling Co. of Chicago, 95 F.3d 627 (jury can infer pretext from employer's failure to explain employment decision at the time)