Bentley v. AutoZoners, LLC, No. 18-2441 (2d Cir. 2019)Annotate this Case
The Second Circuit affirmed the district court's award of summary judgment to defendants on plaintiff's state law claims of sex discrimination, retaliation, and hostile work environment. The court held that summary judgment was correctly entered in favor of AutoZone on plaintiff's Connecticut claims of discriminatory discharge based on sex, retaliatory discharge for reporting sexual harassment, and a sex hostile work environment because plaintiff failed to adduce sufficient evidence from which a reasonable jury could resolve any of these claims in her favor; the district court correctly concluded that plaintiff's own deposition testimony could not raise a genuine issue of fact as to AutoZone's having notice of plaintiff's sexual harassment by a co‐worker before August 2014 because that testimony was unequivocally contradicted by her own earlier sworn and written statements, and she failed plausibly to explain the numerous contradictions; and the district court correctly concluded that plaintiff failed to raise a genuine issue of fact as to the harassing co‐worker being a supervisor, which was required for AutoZone to be strictly vicariously liable for any ensuing hostile work environment.