Wawrzenski

INTRODUCTION

Alexa Wawrzenski was a flight attendant employed by United Airlines, Inc. United investigated and ultimately fired her for having a social media account featuring pictures of herself in uniform and wearing a bikini, with a link to a subscription- based account advertised as providing “[e]xclusive private content you won’t see anywh[ere else].” Wawrzenski sued United, alleging that she endured years of gender discrimination and harassment, that United retaliated against her for complaining about the discrimination and harassment by terminating her employment, that United’s investigation into her social media and her termination discriminated against her as a woman, that United failed to prevent its employees’ misconduct, and that United intentionally caused Wawrzenski emotional distress. United moved for summary judgment or in the alternative for summary adjudication on all causes of action and on Wawrzenski’s claim for punitive damages. The trial court granted United’s motion in its entirety, and Wawrzenski appealed from the ensuing judgment. We conclude the trial court erred in granting United’s motion for summary adjudication on Wawrzenski’s causes of action under…