In Wood v. SatCom Marketing, Wood worked as a Human Resources assistant to the head of HR. During the course of an audit of personnel documents, Wood reported that the files were in order when, in fact, they were unorganized and out of date. Wood was instructed to correct the deficiencies. At about the same time, Wood raised concerns that the employer's practice of requiring electronic direct deposit of employee wages might be illegal. Wood was subsequently placed on a performance improvement plan for thirty days, and immediately delivered a letter to the employer listing various alleged legal violations including the direct deposit policy. That same day, Wood was discharged for violating the terms of her action plan. Wood sued for, among other claims, retaliation for complaining about unlawful pay practices. In dismissing the suit, the federal Eighth Circuit Court of Appeals held that, while Wood had engaged in legally protected activity in complaining about the direct deposit policy, the employer lawfully discharged Wood for legitimate, non-retaliatory reasons, i.e., her repeated failures to perform her job duties, and disregard for explicit instructions to organize and update the HR files.