The recent decision of Cameron-Satchell v. CDHA Management, No. 21-576, 2021 U.S. Dist LEXIS 202877 (Oct. 21, 2021) (Kearney, J.) begins with an observation that could define many employment discrimination cases: "an at-will employee meeting one boss' expectations must understand a new boss may not be satisfied with the same old performance." With an opening sentence like that, it should not be a surprise that the court found there to be no evidence of discrimination or retaliation—but the journey through the facts alleged makes the case worthy of note.

Plaintiff Is Promoted Many Times

Daina Cameron-Satchell was hired as a receptionist in 2013 by CHDA, a children's dental services business. She was promoted numerous times, ultimately rising to become one of three regional managers in 2016. After CHDA was sold to a private equity firm in late 2016, new senior management was installed—including a new president (Michael O'Donnell) and an integrations manager (Julie Amos).