Earl

Plaintiff Christine Earl appeals the district court’s grant of summary judgment on her age and disability discrimination and wrongful termination claims under California law against defendant employer Nielsen Media Research, Inc. (“Nielsen”). Viewing the evidence in the light most favorable to Earl, reasonable jurors could find that Nielsen’s proffered reason for terminating Earl’s employment was a pretext for age discrimination. We therefore reverse the district court’s grant of summary judgment against Earl on her age discrimination and wrongful termination claims. We affirm summary judgment against Earl on her disability discrimination claim.

I. Background

Plaintiff Christine Earl worked more than a dozen years as a Membership Representative, or “recruiter,” for Nielsen in Northern California. Nielsen measures television program audiences and provides the results to advertisers and media outlets. Earl’s job was to recruit households with specified demographics and obtain their consent to install devices relaying their viewing habits back to Nielsen. Nielsen hired Earl in 1994 at age 47.

Earl’s difficulties at work began in August 2005, when she violated a Nielsen…