## Facts

- Laurie Chadwick worked for WellPoint’s Maine office, starting in 1997 and becoming a “Recovery Specialist II” in 1999.
- Her job involved pursuing overpayment and third-party reimbursement claims.
- In 2005 she received strong performance evaluations (4.40 out of 5.00).
- In 2006 she applied for a promotion to “Recovery Specialist Lead” (“Team Lead”), responsible for recovery operations across multiple states.
- Chadwick and Donna Ouelette were finalists; Chadwick had longer tenure in the role and higher performance scores, while Ouelette had shorter tenure and lower performance scores.
- Chadwick had four children under twelve and was taking a college class; her husband served as the primary caretaker during her work hours.
- WellPoint selected Ouelette. When explaining the decision, the hiring supervisor referenced Chadwick’s children and schooling and stated she had “a lot on [her] plate right now,” and suggested others in her position would feel “overwhelmed.”
- Chadwick alleged the non-promotion reflected a sex-based stereotype that mothers of young children are less committed or reliable at work.
- Chadwick sued under Title VII and the Maine Human Rights Act; the district court granted summary judgment for WellPoint and excluded Chadwick’s proposed expert testimony on gender stereotyping.

## Issues

1. Whether the evidence permitted a reasonable jury to find WellPoint denied Chadwick a promotion because of sex-based stereotyping about mothers’ work commitment, in violation of Title VII and the MHRA.
2. Whether the district court abused its discretion by excluding Chadwick’s proposed expert testimony on workplace gender stereotyping.

## Decision

- The court reversed summary judgment for WellPoint on the Title VII and MHRA claims and remanded for further proceedings.
- The court held that the supervisor’s comments tied to Chadwick’s children and schooling, combined with comparative qualifications, could support an inference of sex-based stereotyping.
- The court affirmed the exclusion of Chadwick’s expert testimony, finding no abuse of discretion.

## Legal Principles

- Title VII prohibits discrimination “because of sex,” including employment decisions motivated by sex-based stereotypes.
- Stereotyping that mothers of young children will be less committed, less reliable, or unable to handle added responsibilities can constitute actionable sex discrimination.
- At summary judgment, courts must view evidence and draw reasonable inferences in favor of the nonmoving party; circumstantial evidence may suffice to create a triable issue, and credibility and weight are for the jury.
- Expert testimony may be excluded when it is not sufficiently tied to the case-specific facts or would not materially assist the jury’s assessment of the challenged employment decision.

## Conclusion

The First Circuit held that a jury could reasonably interpret management’s remarks about Chadwick’s childcare responsibilities and schooling as reflecting sex-based stereotypes influencing the promotion decision, making summary judgment improper, while also upholding the trial court’s discretionary exclusion of generalized expert stereotyping testimony.


Chadwick v. WellPoint, Inc., 561 F.3d 38 (1st Cir. 2009)