Articles Posted in US Court of Appeals for the Eighth Circuit

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The Eighth Circuit affirmed the district court's grant of summary judgment to Allina in an action brought by a former employer under the Americans with Disabilities Act (ADA) and the Minnesota Human Rights Act (MHRA), after she was terminated for refusing to fulfill a job requirement that she take necessary steps to develop immunity to rubella. The court held that, although the district court erred in denying plaintiff's inquiry claim based on a lack of injury, summary judgment was proper where Allina's decision to require employees with client contact to complete an inquiry and exam was job-related, consistent with business necessity, and no more intrusive than necessary. Therefore, the health screening that plaintiff was required to take as a condition of her employment complied with the ADA and the MHRA The court also held that the evidence was insufficient to support plaintiff's claim that she was disabled under the ADA where the evidence was insufficient to support the conclusion that plaintiff's chemical sensitivities or allergies substantially or materially limited her ability to perform major life activities. Therefore, plaintiff's failure to accommodate claim failed. Likewise, her retaliation claim failed. View "Hustvet v. Allina Health System" on Justia Law

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The Eighth Circuit affirmed the district court's order granting Steak 'n Shake's motion for summary judgment on plaintiff's Americans with Disabilities (ADA) discrimination claim and his Missouri Workers' Compensation claim. The court held that plaintiff failed to show that he was a qualified individual within the meaning of the ADA. In this case, although he believed that he could perform the essential job functions of a fountain operator, plaintiff's permanent medical restrictions barred him from performing the duties described in the job description. Likewise, plaintiff could not perform the duties of other positions he identified as alternative jobs. View "Denson v. Steak 'n Shake, Inc." on Justia Law

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The Eighth Circuit affirmed the district court's dismissal of a class action brought by over 52,000 experienced and student over-the-road truck drivers, alleging claims under federal and state wage and hour laws. The court held that judicial estoppel was not applicable in this case and that Werner was not bound to previous statements in such a way that affected the outcome of the case. The court also held that, under the Fair Labor Standards Act (FLSA), the mileage-based payments were remuneration for employment and should be included in Werner's minimum wage calculation. Finally, the state law claims were foreclosed as well. View "Baouch v. Werner Enterprises, Inc." on Justia Law

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The EEOC filed suit alleging that North Memorial violated 42 U.S.C. 2000e-3(a), by unlawfully retaliating against an employee. The district court granted summary judgment for North Memorial and dismissed the claim, concluding that North Memorial did not violate section 2000e-3(a) because it did not discriminate against the employee. The Eighth Circuit affirmed and held that the EEOC failed to establish a prima facie case of opposition-clause unlawful retaliation because merely requesting a religious accommodation was not the same as opposing the allegedly unlawful denial of a religious accommodation. The court reasoned that, when an employee or applicant requested a religious accommodation, and the request was denied by an employer such as North Memorial that accommodated reasonable requests that did not cause undue hardship, there was no basis for an opposition-clause retaliation claim under Sec. 2000e-3(a). The court held that the employee or applicant's exclusive Title VII remedy was an unlawful disparate treatment or disparate impact claim under section 2000e-2(a)(1). View "EEOC v. North Memorial Health Care" on Justia Law

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The Eighth Circuit affirmed the district court's grant of summary judgment for Saint Luke's in an employment discrimination action. The court held that the district court did not abuse its discretion in denying defendant's motion to reconsider under Federal Rule of Civil Procedure 60(b)(1). The court explained that, although defendant's delay was brief, Saint Luke's made no claim of prejudice and defendant did not act in bad faith, such factors did not outweigh defendant's carelessness or mistake in construing the rules and the absence of any apparent meritorious defense. Furthermore, there were no exceptional circumstances in this case that warranted relief under Rule 60(b)(6). View "Giles v. St Luke's Northland-Smithville" on Justia Law

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The Eighth Circuit affirmed the district court's grant of summary judgment for defendant in an action alleging that plaintiff's injuries were caused by defendant's negligence in driving a tractor trailer truck. The court held that the workers' compensation benefits plaintiff received were his exclusive remedy against defendant. In this case, defendant and plaintiff entered into an employment relationship in which Swift and Johnson were joint employers mutually liable under Iowa law to provide plaintiff workers' compensation benefits when he suffered a work-related injury, an obligation Swift has fully performed. View "Quiles v. Johnson" on Justia Law

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The Eighth Circuit affirmed the district court's grant of summary judgment for DCDC in an action alleging claims of gender, age, and disability discrimination under state and federal civil rights laws. Plaintiff, a 56 year old woman, worked as a correctional officer until she was injured in inmate altercations. After plaintiff worked the maximum allowable number of days of light duty pursuant to the terms of the Collective Bargaining Agreement (CBA), she was terminated when no other suitable position was found. The court held that plaintiff failed to establish a prima facie case of sex discrimination; plaintiff's prima facie evidence of bad faith supporting her claim of failure to accommodate/disability was rebutted by the incontrovertible evidence that plaintiff could not have been reasonably accommodated; and plaintiff's age discrimination claim failed because she did not produce evidence of a similarly situated younger person who was treated differently. View "Faulkner v. Douglas County" on Justia Law

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At issue in this case was whether the Labor Management Relations Act completely preempts a Minnesota Human Rights Act claim for disability discrimination brought by a former employee of a nuclear power plant. The Eighth Circuit reversed the district court's denial of remand to state court and grant of judgment on the pleadings to the employer, holding that the employee's claim could not be resolved without interpreting a collective-bargaining agreement. The court held that section 301 of the Act completely preempted plaintiff's disability discrimination claim under the Minnesota Human Rights Act; the district court had jurisdiction over the removed matter; and the judgment on the pleadings was properly granted because the section 301 claim was time-barred. View "Boldt v. Northern States Power Co." on Justia Law

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The Eighth Circuit affirmed the district court's grant of summary judgment to Trimark in an action filed by plaintiff, alleging that she was terminated from her job as an executive housekeeper because of her age, in retaliation against her, because she took protected leave, and because she opposed Millennium's discriminatory practices. The court held that plaintiff failed to provide direct evidence that she was retaliated against because of her deposition testimony. Under the McDonnell-Douglas framework, even assuming plaintiff could establish a prima facie case of retaliation, Millennium had clearly shown a legitimate non-discriminatory or retaliatory reason for firing her. In this case, Millennium's internal investigation credibly exposed that plaintiff regularly altered employee hours without using a company-sanctioned form. The court also held that plaintiff failed to show a specific link between any age discrimination and her termination sufficient to support the inference that the discrimination was the cause of her termination. Finally, plaintiff failed to provide any direct evidence that she was fired because she took protected leave under the Family Medical Leave Act. View "Naguib v. Trimark Hotel Corp." on Justia Law

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The Eighth Circuit affirmed the district court's grant of summary judgment for Northern in an action alleging that the company failed to accommodate plaintiff's disability in violation of the Americans with Disabilities Act (ADA). The court held that plaintiff's arguments did not establish a genuine dispute of material fact that Northern did not interact in good faith as a matter of law. Under the circumstances, the timing of Northern's response was insufficient to support a finding that the company did not act in good faith; there was no evidence to support a finding that Northern prematurely abandoned the interactive process; and Northern did not attempt to demonstrate that some other boot would be as effective as a boot that conformed to the performance standards. View "Sharbono v. Northern States Power Co." on Justia Law