In Tunnell v. United Technologies Corp., Pratt & Whitney Division, filed in the U.S. District Court for the District of Connecticut, Joan R. Tunnell, a salaried Procurement Associate, alleged that her employer violated Title VII of the Civil Rights Act of 1964 and the Age Discrimination in Employment Act (ADEA) when she was demoted from her salaried role to an hourly position.
Tunnell, a Black woman over 40, claimed that her 1992 demotion to Engine and Parts Inspector constituted discrimination based on race, sex, and age. She argued that her former role was reassigned to a younger, white male colleague with less experience, despite her satisfactory performance.
At the time of the demotion, Tunnell was in a salaried Grade 42 position, which was eliminated during a company-wide downsizing. The court found that the restructured roles required higher qualifications and more materials experience than Tunnell possessed, and that her comparator, David Hassen, held a higher salaried grade (Grade 46) and had over 14 years of experience.
The court concluded that Tunnell failed to establish a prima facie case of discrimination, emphasizing the difference in pay grade, responsibilities, and experience between Tunnell and Hassen. It granted summary judgment in favor of the employer.
Prima facie refers to the initial evidence that, if accepted as true, is sufficient to support the claim unless rebutted.
Key lessons from the case:
- Holding a salaried position does not preclude lawful demotion during corporate restructuring if objective business reasons and experience-based qualifications are documented.
- Under Title VII and the ADEA, plaintiffs must demonstrate they are similarly situated to comparators and meet the qualifications of the position in dispute.
- Courts will examine employment grade levels and work history when evaluating claims of disparate treatment involving salaried employees.
If you want to know more about salaried employee rights, read our guide on What are my rights as a salaried employee in Connecticut?
