Facts

Kamelia Begley filed suit against her former employer, Delta Dental of California, in relation to the events leading up to the termination of her employment.

PLAINTIFF'S CONTENTIONS: Begley contended that in July 2017, she began requesting occasional time off from work to receive in-vitro fertilization treatment, shared the reason for her absences with her supervisor, and used sick time to cover absences. Begley claimed she took a medical leave between February 26 and March 5, 2018, and her employment was terminated when she returned to work, effective June 1, 2018. Begley alleged that Delta Dental gave her a pretext reason that her position was eliminated in a reorganization, but she was the only employee in Northern California whose position was eliminated. Begley claimed she was unsuccessful in finding another position in the company due to Delta Dental's interference and failure to respond to her inquiries, and her employment was ultimately terminated on June 1, 2018. Begley asserted that Delta Dental terminated her employment in violation of the Fair Employment and Housing Act and California Family Rights Act because of her sex, its perception that she had or was likely to have a pregnancy-related disability, and for taking medical leave.

DEFENDANT'S CONTENTIONS: Delta Dental contended that its evidence established that the company was undergoing a reorganization plan and Begley's performance scores placed her at the bottom of her team in the region, so she was selected as one of 33 employees to be laid off. Delta Dental claimed these employees included men, women without a pregnancy-related disability, and employees who had never taken medical leaves while employed with Delta Dental. Further, Delta Dental argued that Begley was granted all requested medical leave, never made a complaint regarding claims in this action, and did not suffer adverse employment actions for taking protected medical leave.

Result

The court granted Delta Dental of California's motion for summary judgment. The court concluded that, even assuming Begley provided sufficient evidence to establish a prima facie claim for discrimination and retaliation, Delta Dental established a legitimate, non-discriminatory reason for Begley's termination and Begley failed to show that Delta Dental's articulated non-discriminatory reasons were pretextual.