Tiffany Burnett v. AstraZeneca Pharmaceuticals LP

CourtCourt of Appeals for the Fourth Circuit
DecidedMarch 20, 2026
Docket25-1029
StatusUnpublished

This text of Tiffany Burnett v. AstraZeneca Pharmaceuticals LP (Tiffany Burnett v. AstraZeneca Pharmaceuticals LP) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tiffany Burnett v. AstraZeneca Pharmaceuticals LP, (4th Cir. 2026).

Opinion

USCA4 Appeal: 25-1029 Doc: 50 Filed: 03/20/2026 Pg: 1 of 6

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 25-1029

TIFFANY M. BURNETT,

Plaintiff – Appellant,

v.

ASTRAZENECA PHARMACEUTICALS LP,

Defendant – Appellee.

Appeal from the United States District Court for the District of Maryland, at Greenbelt. Lisa W. Wang, Court of International Trade Judge, sitting by designation. (8:22-cv-03335- LWW)

Submitted: November 24, 2025 Decided: March 20, 2026

Before DIAZ, Chief Judge, GREGORY, Circuit Judge, and Gina M. GROH, United States District Judge for the Northern District of West Virginia, sitting by designation.

Affirmed by unpublished opinion. Judge Groh wrote the opinion, in which Chief Judge Diaz and Judge Gregory joined.

ON BRIEF: Pamela L. Ashby, JACKSON & ASSOCIATES LAW FIRM, LLC, Upper Marlboro, Maryland, for Appellant. Lincoln O. Bisbee, New York, New York, Bryan Killian, Brendan J. Anderson, Mathew J. McKenna, MORGAN, LEWIS & BOCKIUS LLP, Washington, D.C., for Appellee.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 25-1029 Doc: 50 Filed: 03/20/2026 Pg: 2 of 6

GROH, District Judge:

In this employment case, Tiffany Burnett asks us to consider whether the district

court incorrectly granted her former employer’s motion for summary judgment. Ms.

Burnett worked for AstraZeneca from 2013 until it terminated her employment on

November 4, 2019. Although the complaint contained eight counts, only Ms. Burnett’s

claims for retaliation and violations of the Equal Pay Act are before us.

I.

We must first address the record in this case. Ms. Burnett’s response to the motion

for summary judgment was untimely filed, and AstraZeneca moved the district court to

strike it. The district court granted AstraZeneca’s motion and struck Ms. Burnett’s

response. However, the court still considered Ms. Burnett’s timely filed cover opposition,

statement of material facts in dispute, exhibits, and proposed order. J.A. 989. The district

court’s ruling on AstraZeneca’s motion to strike is not part of this appeal. We therefore

consider Ms. Burnett’s arguments on appeal within the confines of the record accepted and

utilized by the district court that is unchallenged before us.

II.

Our review of a district court’s grant of summary judgment is de novo. French v.

Assurance Co. of Am., 448 F.3d 693, 700 (4th Cir. 2006). “Summary judgment is

appropriate when there is no genuine issue of material fact and the moving party is entitled

to judgment as a matter of law.” Id.; Fed. R. Civ. P. 56(a). “To create a genuine issue for

trial, ‘the nonmoving party must rely on more than conclusory allegations, mere

speculation, the building of one inference upon another, or the mere existence of a scintilla

2 USCA4 Appeal: 25-1029 Doc: 50 Filed: 03/20/2026 Pg: 3 of 6

of evidence.’” Humphreys & Partners Architects, L.P. v. Lessard Design, Inc., 790 F.3d

532, 540 (June 24, 2015) (quoting Dash v. Mayweather, 731 F.3d 303, 311 (4th Cir.2013)).

III.

“To make a prima facie claim of retaliation, a plaintiff must show: (1) that she

engaged in protected activity, (2) that the employer took a materially adverse action against

her and (3) there is a causal connection between the protected activity and the adverse

action.” Evans v. Int'l Paper Co., 936 F.3d 183, 195 (4th Cir. 2019) (citing Burlington N.

& S.F.R. Co. v. White, 548 U.S. 53, 61–68 (2006); King v. Rumsfeld, 328 F.3d 145, 150–

51 (4th Cir. 2003)).

Ms. Burnett presents two retaliation theories. First, she claims that after complaining

about her pay, AstraZeneca retaliated by firing her. Second, she avers that it retaliated

against her by barring her from finding another position. The facts support neither theory.

AstraZeneca reorganized Ms. Burnett’s team in 2019. J.A. 142. Because Ms.

Burnett was not selected to become part of the new team, AstraZeneca gave her 60 days to

find another position. J.A. 142–43. Similarly situated individuals received the same deal.

Id.; J.A. 37–38. However, Ms. Burnett received a dedicated internal recruiter to assist her

with her job search even though none of the other employees displaced by the

reorganization received one. J.A. 38.

Ten days after receiving her 60-day notice, Ms. Burnett emailed AstraZeneca’s

general counsel to raise allegations of pay inequity and retaliation. J.A. 183–85. Ms.

Burnett only applied to a few positions, and they were all in research and development.

J.A. 735–37; J.A. 744. She did not find another position, so AstraZeneca terminated her—

3 USCA4 Appeal: 25-1029 Doc: 50 Filed: 03/20/2026 Pg: 4 of 6

just like it told her it would. J.A. 38. The district court held that Ms. Burnett failed to

establish any causal connection between her email to AstraZeneca’s General Counsel (the

protected activity) on September 9, 2019, and her termination from the company on

November 1, 2019. J.A. 1006-07.

When a company tells an employee that it is going to follow specific steps regarding

an employee’s termination, and then it follows the plan it outlined, courts cannot presume

that the company fired the employee in retaliation for some intervening protected activity.

See Clark Cnty. Sch. Dist. v. Breeden, 532 U.S. 268, 272 (2001). That is the exact fact

pattern this case presents. In short, Ms. Burnett fails to show retaliation caused her firing.

Nor has she shown that AstraZeneca retaliated against her by preventing her from

securing another role in the company. If anything, AstraZeneca gave Ms. Burnett extra

help when compared to others. Sanne Bellemans, whom Ms. Burnett claims retaliated

against her, was not involved in research and development hiring. J.A. 943–44. Ms. Burnett

has not cited any evidence beyond her own speculation that Bellemans played any role in

“prevent[ing] her from obtaining another position.” Appellant’s Br. at 22.

Ms. Burnett similarly fails to establish that the individuals who made hiring

decisions in research and development knew about her pay-equity complaint when they

did not hire her for those positions. Accordingly, Ms. Burnett cannot adequately make a

claim that those hiring managers selected other candidates to retaliate against her. See

Roberts v. Glenn Indus. Grp., Inc., 998 F.3d 111, 122 (4th Cir. 2021) (knowledge of the

protected activity by the decisionmaker “is absolutely necessary to establish . . . a prima

facie case.” (citation omitted)).

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The district court correctly found that Ms. Burnett presented no evidence of

retaliation beyond her own mere speculation. Because no evidence of retaliation exists,

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