The Second Circuit on Thursday upheld the dismissal of a lawsuit filed by a Trader Joe’s executive who alleged her termination was based on sex discrimination. The court determined that Tracy Flanagan, a former regional vice president overseeing stores in Connecticut and New York, failed to provide sufficient evidence that her firing was motivated by bias rather than her decision to vacation during the onset of the COVID-19 pandemic.
In a unanimous decision, the three-judge panel granted summary judgment in favor of Trader Joe’s East Inc. Flanagan had pursued claims under Title VII and the Connecticut Fair Employment Practices Act, but the judges concluded that her allegations lacked substantive proof connecting her dismissal to sex discrimination.
Trader Joe’s provided a legitimate reason for Flanagan’s termination, the panel stated. Despite directives issued to regional vice presidents to limit travel during the escalating COVID-19 crisis in March 2020, Flanagan chose to take a vacation in Mexico. This decision came just days after employees at the grocery chain were deemed essential workers, and leadership was asked to prioritize their responsibilities amid the pandemic.
