Pierce v. Zoetis, Inc., No. 15-1900 (7th Cir. 2016)
Annotate this CaseIn 2012, Pierce began working as a Zoetis sales representative. Pierce had several unpleasant encounters with her supervisor, Heuchert, and others. Pierce complained about Heuchert’ to Human Resources, which she alleges, prompted retaliation. Zoetis’ human resources director initiated an investigation, after which all sales representatives were notified that their sales quotas were being adjusted. Pierce alleges that her quotas were adjusted upward more substantially than those of other employees. Pierce also attributes increased difficulty in receiving expense reimbursements to retaliation. In 2013, Pierce took time off for foot surgery. Around that same time, Human Resources informed Pierce that the investigation had concluded and that Heuchert would be disciplined. Pierce returned to work, but was fired three weeks later for failure to meet the increased sales goals. Pierce sued, alleging Indiana state-law claims of wrongful termination and tortious interference with a business relationship. The district court dismissed, citing Indiana’s employment at will doctrine and noting that Pierce failed to follow prerequisites for bringing suit under the Indiana Civil Rights Law. The Seventh Circuit affirmed. Most of the behavior Pierce identified in her complaint was taken within the scope of Heuchert’s duties as Pierce’s manager, and could not form the basis of a tortious interference claim.
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