## Facts

- M. Jane Minor worked as a sales representative for Centocor, selling products to physicians and hospitals.
- After Antonio Siciliano became her supervisor, he required sales representatives to visit all accounts twice monthly and major accounts more frequently.
- Minor asserted these requirements increased her workweek from roughly 50–55 hours to 70–90 hours, much of it driving, and that she received frequent critical emails and close supervision.
- In August 2001 Minor experienced atrial fibrillation and depression; by October 2001 she stopped working.
- Centocor and the Social Security Administration determined Minor was disabled, and she received disability benefits.
- Minor alleged the increased demands and supervision were imposed because of her sex (Title VII) and age (ADEA) and sought damages measured by the difference between disability benefits and the earnings she claimed she would have made if she had continued working.
- The record contained no direct evidence of sex- or age-based bias, and Minor proceeded under the indirect, burden-shifting method of proof.

## Issues

1. Whether increased workload, heightened supervision, and critical communications—without firing, demotion, or formal discipline—constituted an actionable adverse employment action under Title VII and the ADEA.
2. Whether Minor produced sufficient evidence of sex- or age-based disparate treatment, including that similarly situated employees outside her protected classes were treated more favorably.
3. Whether Minor produced sufficient evidence of disparate impact, including that a facially neutral policy disproportionately burdened women or older workers as a group.

## Decision

- The Seventh Circuit affirmed summary judgment for Centocor.
- The court concluded Minor failed to produce evidence supporting either disparate treatment or disparate impact based on sex or age.
- The court noted the challenged visitation requirements applied to all sales representatives supervised by Siciliano, with no showing that Minor was singled out.
- The court treated Johnson & Johnson (Centocor’s parent) as not a proper party.

## Legal Principles

- Under Title VII and the ADEA, demanding work conditions and close supervision generally are not actionable absent proof connecting them to discrimination based on a protected characteristic.
- Under the indirect method, a plaintiff must present evidence permitting an inference of discrimination, commonly by showing less favorable treatment than similarly situated employees outside the protected class.
- Disparate impact requires evidence that a facially neutral policy disproportionately affects a protected group, not merely that it was unusually burdensome for a single employee.
- Where an employer articulates a neutral, business-based explanation for workload expectations, a plaintiff must offer evidence from which a reasonable jury could reject that explanation as a cover for prohibited discrimination.

## Conclusion

The court held that even if the workload and supervision were onerous and contributed to Minor’s inability to work, her claims failed because she did not link the challenged expectations to sex or age discrimination through comparative proof, evidence of animus, or group-based disparate impact.


Minor v. Centocor, Inc., 457 F.3d 632 (7th Cir. 2006)