Laid-off Sheriff's Department employee did not prove gender discrimination

In Syrowatka v. Washtenaw County, the Court of Appeals held that the plaintiff failed to prove that her lay-off was gender discrimination.  The court held that the plaintiff's one complaint about pay disparity two years earlier was not adequate to prove a retaliatory nexus. 

The appellate panel also held that evidence of discriminatory statements by the Sheriff and his alleged manipulation to eliminate her position were not adequate to establish illegal discrimination.  The Court pointed to an alleged workforce reduction caused by economic conditions, and held that the lapse of ten months between reassigning her and eliminating the new position rendered her discharge claim "speculative".  If the Sheriff was discriminating, he apparently covered his tracks adequately.