Despite the decisionmaker’s statement questioning the postmaster’s energy for one position, the court granted summary judgment against her age discrimination claims.
A postmaster who, at the age of 58, was denied two promotions to younger men and was told by her supervisor when she applied for the second position that the post office had never had a female postmaster and she wondered how that would work, and who also questioned whether she would have the energy to manage the office, failed to show she was denied both promotions due to her age or that she was denied the first because of her sex, the First Circuit concluded. Reversing summary judgment against her Title VII sex discrimination claim as to the second promotion, however, the appeals court found the employee’s evidence, taken together, was “just enough to warrant a jury trial” (Warner v. DeJoy, No. 24-1414 (1st Cir. Sept. 4, 2025)).


