Caraballo-Caraballo v. Correctional Administration, No. 16-1597 (1st Cir. 2018)Annotate this Case
The district court correctly granted summary judgment to the Defendant regarding Plaintiff’s hostile work environment and retaliation claims but erred in analyzing Plaintiff’s disparate treatment claim.
After Plaintiff was transferred and replaced by one male employee and then by a second male employee, Plaintiff filed this Title VII gender discrimination action against her employer, the Corrections Department of the Commonwealth of Puerto Rico. The district court granted summary judgment to Defendant on all of Plaintiff’s claims. The First Circuit vacated in part the grant of summary judgment and remanded for further proceedings on Plaintiffs’ disparate treatment claim. The Court held (1) the district court erred in interpreting this Court’s decision in Johnson v. University of Puerto Rico, 714 F.3d 48 (1st Cir. 2013), to prohibit Plaintiff from relying on evidence highly relevant to the similar qualifications element of her prima facie case; and (2) Plaintiff established a prima facie case of gender discrimination that her employer failed to rebut, and therefore, summary judgment was incorrectly granted in the Department’s favor.