Proof of a "glass ceiling" and illegal sex discrimination can be found from the following: (1) slower promotions for a better-qualified woman than a lesser-qualfied male; (2) when the promotion comes it is to a lesser salary range; (3) what is styled a promotion is actually to a lesser title and lower pay than the male predecessor; (4) lesser opportunities for advancement and training; and, (5) writings of a company CEO praising gender-biased management styles. A reasonable jury could find this evidence proof of a glass ceiling and sex discrimination the Sixth Circuit ruled recently in Conti v. American Axle, No. 08-1301 (May 22, 2009).

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