Langenbach v. Wal-Mart Stores, Inc.

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Langenbach began stocking shelves for Wal-Mart in 1998. The next year, she was promoted. In 2001, she was again promoted. Langenbach was admitted to Wal-Mart’s Management-In-Training program in 2008. In her first evaluation as an Assistant Manager, she was rated as a “Solid Performer” with noted deficiencies. Later that year, Langenbach was placed on a Performance Improvement Plan. The PIP was never completed. Her managers did not hold the anticipated follow-up meetings. She later received a comment that she was not following management routines and frequently failed to complete her duties on time. At her 2010 review, Langenbach received a competency score of 2.63 out of 5 and a rating of “Development Needed,” noting specific issues. That month, Langenbach needed surgery and was granted leave under the Family and Medical Leave Act. Her next evaluation assessed overall competency at 2.26 out of 5 and rated her as “Development Needed.” Langenbach was again placed on a Performance Improvement Plan. At three follow-up sessions, she was rated as “Below Expectations.” She was terminated five months after returning from leave. The district court rejected claims that Wal-Mart retaliated against her for exercising her FMLA rights and discriminated against her by delaying her promotion, paying her less than her male counterparts, and refusing to promote her further. The Seventh Circuit affirmed.View "Langenbach v. Wal-Mart Stores, Inc." on Justia Law