Court Divides Over Former MetLife Executive’s Lawsuit Alleging Sexist Responsibilities

A federal appeals court was split on whether to revive the sex discrimination lawsuit of a former MetLife Group Inc. executive who claimed she was required to perform stereotypically feminine administrative tasks due to her gender.

Chief Judge William Pryor argued during oral argument that Marybeth Lukie’s claims of gender bias were not valid, citing the infrequency of the assignments and their professional nature rather than administrative. He also noted that Lukie did not raise any concerns about being assigned feminized work at the time.

Judges Robin Rosenbaum, an Obama appointee, and Nancy Abudu, a Biden appointee, expressed concern about the gender dynamics of some of Lukie’s tasks, indicating a potential division within the panel.

The court’s ruling on Lukie’s claim of a sexist division of labor could bring clarity to Eleventh Circuit law regarding whether such treatment constitutes an adverse employment action that supports a sexual discrimination claim.

Disputes over what employer decisions are actionable under anti-discrimination law have been a subject of contention in federal circuit courts in recent years. The court’s decision in Lukie’s case could have broader implications in this legal landscape.

Lukie, who worked as a vice president in MetLife’s enterprise risk group, alleged that the company required her to perform demeaning, feminized secretarial tasks, such as taking notes in meetings and preparing documents.

Despite the appeals court’s concerns, a federal judge in the Middle District of Florida dismissed Lukie’s claim about work assignments due to the lack of a demonstrated economic impact.

Professional or Administrative?

Lukie also appealed the judge’s decision to dismiss her claims of pay disparity and retaliation by MetLife. However, the Eleventh Circuit showed little support for reviving her pay discrimination allegation.

The case is Lukie v. MetLife Group, Inc., 11th Cir., No. 22-10967, oral argument held 12/14/23.