Mary Crawford v. Sandra Wozniak

── Mary Crawford v. Sandra Wozniak ── Court: Court of Appeals for the Third Circuit Date: April 16, 2026 Category: General U.S. COURT OF APPEALS FOR THE THIRD CIRCUIT No. 25-1932 MARY CRAWFORD, Appellant v. SANDRA WOZNIAK; ZALES DELAWARE, INC.; ABC CORPORATIONS 1-5, fictitious names describing presently unidentified business entities; and JOHN DOES 1-5, fictitious names describing presently unidentified individuals ________________________ Appeal from the U.S. District Court, D.N.J. Judge Edward S. Kiel No. 1:21-cv-15811 Before: PORTER, MONTGOMERY-REEVES, and BOVE, Circuit Judges Submitted: Apr. 10, 2026; Decided: Apr. 16, 2026 _____________________________ NONPRECEDENTIAL OPINION ∗ MONTGOMERY-REEVES, Circuit Judge. In this appeal, Mary Crawford seeks to reinstate her claims against Zales Delaware, Inc. (“Zales”) and Sandra Wozniak for violations of the New Jersey Law Against Discrimination (“NJLAD”). N.J. Stat. Ann. §§ 10:5-1 to -50. Because we see no genuine disputes of material fact for her claims, we will affirm the District Court’s order granting summary judgment. ∗ This disposition is not an opinion of the full Court and, under I.O.P. 5.7, is not binding precedent.  I. BACKGROUND 1 From 2015 to 2019, Crawford worked at two Zales locations. She was the oldest employee at both. Three of her colleagues, including Wozniak, made numerous negative comments about Crawford’s age. She reported them, but nothing happened, and the comments continued. During the same time, coworkers and managers complained about Crawford’s workplace behavior. 2 On August 10, 2019, Crawford’s regional manager Phillip Avitabile fired her, citing these complaints as the basis for the termination. In 2021, Crawford filed her complaint against Zales and Wozniak. She alleged that Zales discriminated against her based on age, created a hostile work environment, and retaliated against her for complaining about the ageist environment at Zales—all in violation of the NJLAD. She also alleged that Wozniak aided and abetted Zales’s violations of the NJLAD. After discovery, Zales and Wozniak moved for summary judgment. The District Court granted their motion. This appeal followed. 1 We view the following facts in the light most favorable to Crawford, the non-movant. Turco v. City of Englewood, 935 F.3d 155, 161 (3d Cir. 2019). 2 These concerns included Crawford (1) being written up for excessive lateness and call outs; (2) entering the store after closing in violation of policy; (3) participating in an incident consistent with insurance fraud; (4) changing shifts without proper approval; (5) sharing personal information about other jewelry consultants with customers; (6) intervening with other jewelry consultants’ sales; (7) having verbal altercations with her co-workers and displaying her anger at them in front of customers; (8) abusing premier rewards; (9) making disparaging comments about customers and making them cry; and (10) engaging in dishonest behavior. Appendix (hereinafter “App. __”) 4; App. 740–41. 2  II. ANALYSIS3 Crawford argues that the District Court erred in granting summary judgment because a genuine dispute of material fact exists for her discrimination, hostile-work- environment, retaliation, and aiding-and-abetting claims. We disagree. First, discrimination. Under the NJLAD, it is “unlawful discrimination” to “discharge” an employee “because of . . . age.” N.J. Stat. Ann. § 10:5-12(a). New Jersey courts assessing NJLAD discrimination claims em