Quinlan v. Elysian Hotel Co.

916 F. Supp. 2d 843, 2013 WL 65982, 2013 U.S. Dist. LEXIS 1698, 116 Fair Empl. Prac. Cas. (BNA) 1731
CourtDistrict Court, N.D. Illinois
DecidedJanuary 4, 2013
DocketNo. 11 C 5956
StatusPublished
Cited by2 cases

This text of 916 F. Supp. 2d 843 (Quinlan v. Elysian Hotel Co.) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Quinlan v. Elysian Hotel Co., 916 F. Supp. 2d 843, 2013 WL 65982, 2013 U.S. Dist. LEXIS 1698, 116 Fair Empl. Prac. Cas. (BNA) 1731 (N.D. Ill. 2013).

Opinion

Memorandum Opinion and Order

EDMOND E. CHANG, District Judge.

Plaintiff Bridget Quinlan alleges that her former employer, Defendant Elysian Hotel, fired her in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq., and the Pregnancy Discrimination Act of 1978, 42 U.S.C. § 2000e(k)1 Quinlan also claims that Elysian Hotel interfered with her rights under the Family and Medical Leave Act, 29 U.S.C. § 2601 et seq., and created a hostile work environment. Elysian moves for summary judgment on all counts. R. 24. For the following reasons, Elysian’s motion is granted in part and denied in part: the Title VII claim survives, but the FMLA and harassment claims do not.

I. Factual Background

In deciding this summary judgment motion, the Court views the evidence in the light most favorable to the non-movant, Quinlan. In May 2008, Elysian Hotel2 hired Quinlan to be its public relations director. R. 26, Def.’s Stmt, of Facts (DSOF) ¶ 2. At the time, Elysian was an entirely new construction project, and a completely unknown hotel brand. DSOF ¶ 5. As the public relations director, Quinlan was expected to generate positive press, manage Elysian’s image, manage photo shoots, entertain media, and coordinate the hotel’s charitable outreach. DSOF ¶ 6. Early on, Elysian’s director of marketing, Gianna Tetrick, was Quinlan’s supervisor. DSOF ¶ 19.

Elysian was expected to open in the spring 2009, but the opening was delayed several times. DSOF ¶ 14. In December 2009, Elysian fired Tetrick, and Joseph Aguilera, vice president of marketing and sales, took over as Quinlan’s supervisor. DSOF ¶¶ 9, 19. Mary Beth Malone, one of Elysian’s investors who had overseen construction of the hotel, also took on market[846]*846ing duties at that time and eventually became the marketing director. DSOF ¶¶ 8, 21. Later that month, Elysian opened its doors. DSOF ¶ 19.

In February 2010, Quinlan informed her supervisors, Aguilera and Malone, that she was pregnant. DSOF ¶ 26. In the following months, Elysian’s occupancy rates began to increase. DSOF ¶ 30. By April, the hotel was extremely busy, and the workloads of Elysian employees increased as well. DSOF ¶¶ 30, 34-35. Quinlan had been juggling her public relations responsibilities along with the marketing work that came her way. DSOF ¶ 35. But Quinlan gradually began to handle more of the marketing responsibilities, and her hours increased to between 50 and 60 hours per week. DSOF ¶ 35-36. In fact, Quinlan was the only employee performing tasks related to marketing work under Aguilera and Malone’s supervision. DSOF ¶ 40.

By May 2010, it was clear that Elysian was losing more money in 2010 than originally forecasted, and the hotel began to cut costs. DSOF ¶¶ 44, 46-47. In January 2011, Kevin Robinson (Elysian’s general manager) asked the hotel planning committee to identify salaried positions that Elysian could eliminate without affecting the hotel’s performance. DSOF ¶¶ 9, 66-67. Aguilera suggested that Elysian could operate without an on-site director of public relations, and the planning committee agreed. DSOF ¶¶ 68, 71-73. Ultimately, Robinson and the hotel’s development partners approved of the committee’s assessment, and Quinlan was fired in February 2011. DSOF ¶¶ 74-75.

II. Standard of Review

Summary judgment is required “if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed.R.CivJP. 56(a). Rule 56 “mandates the entry of summary judgment, after adequate time for discovery and upon motion, against a party who fails to make a showing sufficient to establish the existence of an element essential to that party’s case, and which that party will bear the burden of proof at trial.” Celotex Corp. v. Catrett, 477 U.S. 317, 322, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986). All facts, and any inferences to be drawn from them, must be viewed in the light most favorable to the non-moving party. Wis. Cent., Ltd. v. Shannon, 539 F.3d 751, 756 (7th Cir.2008).

III. Title VII

Quinlan argues that she was fired because of her sex and pregnancy. See generally R. 37 (Pl.’s Br.). Title VII prohibits employment discrimination on the basis of sex. 42 U.S.C. § 2000e-2(a). In 1978, Congress amended Title VII by enacting the Pregnancy Discrimination Act, which explicitly barred discrimination on the basis of pregnancy:

The terms “because of sex” or “on the basis of sex” include, but are not limited to, because of or on the basis of pregnancy, childbirth, or related medical conditions; and women affected by pregnancy, childbirth, or related medical conditions shall be treated the same for all employment-related purposes ... as other persons not so affected but similar in their ability or inability to work ....

42 U.S.C. § 2000e(k). “The [Pregnancy Discrimination Act] created no new rights or remedies, but clarified the scope of Title VII by recognizing certain inherently gender-specific characteristics that may not form the basis for disparate treatment of employees.” Hall v. Nalco Co., 534 F.3d 644, 647 (7th Cir.2008) (citing Newport News Shipbuilding & Dry Dock Co. v. EEOC, 462 U.S. 669, 678-79, 103 S.Ct. 2622, 77 L.Ed.2d 89 (1983)). “The [Pregnancy Discrimination Act] ‘made clear that, for all Title VII purposes, discrimination based on a woman’s pregnancy is, on [847]*847its face, discrimination because of her sex.’ ” Id. (quoting Newport News, 462 U.S. at 684, 103 S.Ct. 2622); see also Griffin v. Sisters of Saint Francis, Inc., 489 F.3d 838, 843 (7th Cir.2007) (stating that “pregnancy is a proxy for gender, and, therefore, discrimination against pregnancy is discrimination against women”).

Quinlan argues that she has sufficient evidence to show sex discrimination using the direct method of proof.3 Quinlan presents a series of statements and conduct that she believes create a mosaic of circumstantial evidence of discrimination. Many of these statements are detailed in the affidavit Quinlan submitted in response to Elysian’s motion for summary judgment. See R. 36-1 (Quinlan Deck). Elysian argues that the Court should disregard much of Quinlan’s affidavit because it contradicts her previous deposition testimony. R. 39 (Def.’s Reply) at 7-10. Thus, the Court’s first task is to determine which of Quinlan’s statements can be considered in deciding this summary judgment motion.

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916 F. Supp. 2d 843, 2013 WL 65982, 2013 U.S. Dist. LEXIS 1698, 116 Fair Empl. Prac. Cas. (BNA) 1731, Counsel Stack Legal Research, https://law.counselstack.com/opinion/quinlan-v-elysian-hotel-co-ilnd-2013.