While Title VII’s coverage is broad, courts have repeatedly held that it does not prevent "child care" discrimination. In the recent case of Zaengle v. Rosemount, No. 08-2010 (E.D. Pa. May 17, 2013) (Ludwig, J.), however, the U.S. District Court for the Eastern District of Pennsylvania held that a supervisor’s repeated comments to a single mother to the effect that she was spending too much time with her children, coupled with evidence of disparate treatment, created a triable issue of gender discrimination.
Ten Years of Sales Success
Kathryn Zaengle began working in 1993 as a salesperson for Rosemount Inc., a manufacturer of temperature and pressure control instruments. For the first 10 years of her employment, she was a highly-rated performer, such that she became a "Level 5" salesperson the pinnacle of sales rankings at the company. In reaching this level, she was supported by her supervisor, Tom Thomas. Despite his substantively high ratings for Zaengle, Thomas’ evaluations often referred to Zaengle’s "personal life," "family demands" and "children," according to the opinion. None of the evaluations of the 11 other salespersons in her unit (all men) contained such references.
