Supreme Court of Vermont
Lynne Robertson v. Mylan Laboratories, Inc., Bertek, Inc. and Sharad Govil
February 6, 2004176 Vt. 356
Summary
The court affirmed summary judgment for the defendants on the plaintiff's FEPA claims alleging gender-based failure to promote, unequal pay, disparate treatment, and retaliation. It held that the circumstantial evidence required the burden-shifting framework, that plaintiff established a prima facie failure-to-promote case but failed to show the employer's restructuring rationale was pretextual, and that her retaliation evidence did not establish the required adverse action and causal connection or pretext. The court also concluded that the unequal-pay and poor-treatment claims failed at the prima facie stage.