Justia U.S. 8th Circuit Court of Appeals Opinion Summaries

The case revolves around Thomas Clobes, a Christian employee at a 3M manufacturing plant in Minnesota, who objected to 3M's COVID-19 vaccination policy on religious grounds. Clobes was told he would be terminated if he did not get vaccinated. He submitted a religious accommodation request to 3M, asking to continue with the same accommodations he had been following, such as wearing a mask and maintaining social distance. 3M did not immediately grant the request and asked Clobes follow-up questions about his religious beliefs and objections to the vaccine. Meanwhile, 3M continued to send daily email and loudspeaker announcements urging employees to get vaccinated. However, the vaccine requirement was eventually lifted due to the Federal Contractor Mandate being enjoined.In the District Court of Minnesota, Clobes sued 3M, alleging religious discrimination and a hostile work environment under Title VII of the Civil Rights Act of 1964 and the Minnesota Human Rights Act (MHRA). The district court granted 3M's motion to dismiss, ruling that Clobes failed to demonstrate that he suffered an adverse employment action or that similarly situated non-Christians were treated differently by 3M. The court also found that Clobes failed to allege any conduct on 3M's part that rose to the level of severe or pervasive harassment, and that there was no causal connection between Clobes's religion and 3M's conduct. The court denied Clobes leave to amend his complaint, reasoning that amendment would be futile as Clobes failed to identify any additional facts that would establish a viable claim.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court found that Clobes's complaint failed to plausibly support the elements of a hostile work environment claim, namely, that a causal nexus existed between 3M's allegedly harassing conduct and Clobes's status as a Christian, and that the harassment affected a term, condition, or privilege of employment. The court also upheld the district court's denial of leave to amend the complaint, as Clobes had not complied with the local rules requiring a copy of the proposed amended pleading to accompany any motion to amend. View "Clobes v. 3M Company" on Justia Law

In December 2019, Tonya Huber, a store manager for Westar Foods, Inc., missed work due to a diabetic episode. Shortly after, Westar fired her. Huber sued Westar, alleging disability discrimination under the Americans with Disabilities Act (ADA) and Nebraska Fair Employment Practices Act (NFEPA), and interference with and retaliation for exercising her rights under the Family and Medical Leave Act (FMLA). Westar filed a motion for summary judgment, which the district court granted. Huber appealed.The district court granted Westar's motion for summary judgment, concluding that Huber failed to present direct evidence of disability discrimination and that she did not meet her burden under the McDonnell Douglas burden-shifting framework to show that Westar's reason for firing her was pretextual. The court also found that Huber failed to show that Westar interfered with her FMLA rights or retaliated against her for exercising those rights.The United States Court of Appeals for the Eighth Circuit reversed and remanded the case for further proceedings. The court found that genuine issues of fact existed regarding whether Westar's reason for firing Huber was pretextual and whether Westar interfered with or retaliated against Huber for exercising her FMLA rights. The court concluded that a reasonable jury could find that Westar's termination decision was motivated by discriminatory animus and that Westar interfered with Huber's FMLA rights. The court also found that genuine issues of fact existed regarding whether Huber provided Westar with notice of her need for FMLA leave as soon as practicable and whether there was a causal connection between her FMLA rights and Westar's termination decision. View "Huber v. Westar Foods, Inc." on Justia Law

A physical therapist, Pamela Cole, filed a lawsuit against her employer, Group Health Plan, Inc., alleging religious discrimination under Title VII and the Minnesota Human Rights Act. Cole, a member of the Eckankar religion, objected to the company's COVID-19 vaccine mandate on religious grounds. Although the company exempted her from the mandate, it imposed conditions such as wearing a medical-grade mask and potentially being reassigned to a different work setting. Cole argued that these conditions, along with a badge system that publicly identified vaccination status, singled out unvaccinated employees and subjected them to ridicule and criticism.The District Court for the District of Minnesota dismissed Cole's complaint, ruling that she failed to state a claim. Cole appealed this decision to the United States Court of Appeals for the Eighth Circuit.The Eighth Circuit Court reviewed the dismissal de novo, meaning it considered the case anew, as if no decision had been previously made. The court found that Cole had plausibly alleged a claim of disparate treatment, a form of religious discrimination. The court noted that Cole had sufficiently alleged that she was a member of a protected class due to her religious beliefs, that she met her employer's legitimate expectations, and that the circumstances gave rise to an inference of discrimination. The court also found that whether Cole had suffered an adverse employment action, a key element of a discrimination claim, required further factual development.The Eighth Circuit Court reversed the district court's decision, remanding the case for further proceedings. The court concluded that dismissal of the complaint on the basis of no adverse action was improper at this stage of the proceedings. View "Cole v. Group Health Plan, Inc." on Justia Law

Robert Wayne Goosen, an employee of the Minnesota Department of Transportation (MNDOT), suffered an on-the-job injury in 2018 that required multiple surgeries and physical therapy. In 2021, after reaching his maximum medical improvement, Goosen's doctor determined that he could return to work with certain physical restrictions. However, MNDOT concluded that Goosen could not perform the essential functions of his job due to these restrictions and could not be reasonably accommodated. Goosen subsequently filed a lawsuit alleging that MNDOT violated the Americans with Disabilities Act (ADA) by failing to provide a reasonable accommodation.The district court granted MNDOT's motion for summary judgment. The court found that no reasonable jury could conclude that Goosen was qualified to perform the essential functions of his former position or that a reasonable accommodation was possible. Goosen appealed this decision.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court agreed with the lower court's determination that Goosen could not perform the essential functions of his job, even with reasonable accommodation. The court also found that Goosen failed to make a facial showing that reassignment to a different position within MNDOT was a reasonable accommodation. The court concluded that Goosen did not provide sufficient evidence to support his claim that MNDOT violated the ADA. View "Robert Goosen v. Minn. Dept. of Transportation" on Justia Law

This case is a class action involving commercial truck drivers who claimed they were not paid properly by Werner Enterprises, Inc., and Drivers Management, LLC. The drivers alleged that they were not adequately compensated for off-duty time spent on short rest breaks and time spent resting in their trucks’ sleeper-berths. The case has been appealed multiple times, with the court previously vacating a jury verdict in favor of the drivers because the district court improperly allowed the drivers to submit an expert report after the deadline. On remand, the district court entered judgment in favor of the defendants. The drivers appealed again, and the court vacated the judgment and remanded the case back to the district court to conduct an analysis regarding whether the expert report should be excluded as a discovery sanction and whether the district court should appoint an independent expert.On remand, the district court concluded that exclusion of the drivers’ expert report was the appropriate sanction for its late disclosure and that appointment of an independent expert was not appropriate. It then entered judgment in favor of the defendants. The drivers appealed this decision, asserting that the district court erred in its analysis. The defendants cross-appealed, asserting that the drivers’ notice of appeal was untimely, requiring dismissal of the appeal.The United States Court of Appeals for the Eighth Circuit rejected the defendants’ contention on cross-appeal and affirmed the judgment of the district court. The court found that the district court did not abuse its discretion in excluding the expert report and denying the drivers’ motion for a new trial. The court also found that the district court did not err in declining to appoint an expert and in entering judgment in favor of the defendants. View "Petrone v. Werner Enterprises, Inc." on Justia Law

Leroy Johnson, a supervisor at Westinghouse Air Brake Technologies Corporation (Wabtec), was terminated after failing to fully disclose his contact with a COVID-19 positive individual, violating the company's COVID-19 protocols and a Last Chance Agreement he had signed. Johnson, the only salaried black employee at the plant, sued Wabtec for wrongful termination under the Missouri Human Rights Act (MHRA), Title VII of the Civil Rights Act of 1965, and the Age Discrimination in Employment Act (ADEA). The district court granted summary judgment in favor of Wabtec.The district court's decision was based on the conclusion that Johnson had not established a prima facie case of discrimination. Johnson had argued that he was treated less favorably than similarly situated white employees, but the court found that the employees he cited were not similarly situated as they were not terminated for misconduct. The court also found that Johnson's failure to fully disclose his potential COVID-19 exposure constituted a safety concern and misconduct, which was grounds for termination under the Last Chance Agreement.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court agreed that Johnson had not established a prima facie case of discrimination and that his termination was due to his misconduct, not his race or age. The court also noted that Johnson had waived his ADEA claim by failing to address its merits in his opening brief. View "Johnson v. Westinghouse Air Brake Technologies Corporation" on Justia Law

Samantha Howard, a pharmacist with Type I diabetes and hypoglycemic unawareness, began working at Bothwell Regional Medical Center, operated by the City of Sedalia, Missouri. Howard requested to keep food and drink at her desk, which was granted. Later, she requested to bring a service dog into the pharmacy to help her manage her diabetes. Bothwell denied this request, citing potential risks of contamination. Unable to agree on an alternative accommodation, Howard resigned and filed a lawsuit alleging that Bothwell's failure to make a reasonable accommodation violated the Americans with Disabilities Act (ADA). The jury ruled in favor of Howard, awarding her compensatory and emotional damages. Bothwell appealed the district court's denial of its motion for judgment as a matter of law.The United States Court of Appeals for the Eighth Circuit reviewed the denial of a motion for judgment as a matter of law de novo. The court found that the case was governed by its recent decision in Hopman v. Union Pac. R.R., which clarified the definition of "reasonable accommodation" under the ADA. The court concluded that Howard failed to identify any employer-sponsored benefit or program to which she lacked access due to the absence of her service dog. The court ruled that providing a service dog at work so that an employee with a disability has the same assistance the service dog provides away from work is not a cognizable benefit or privilege of employment. Therefore, the court reversed the district court's order and remanded the case with instructions to enter judgment in favor of Bothwell. View "Howard v. City of Sedalia, Missouri" on Justia Law

Matthew Meinen, a white male, filed a lawsuit against his former employer, Bi-State Development Agency, alleging racial and gender discrimination, hostile work environment, and retaliation. Meinen claimed that he was harassed by an unidentified female African American co-worker, who made inappropriate comments and physical contact. He reported these incidents to his and her supervisors. In March 2021, during an unrelated investigation, Meinen informed a Bi-State human resources employee about his concerns. He was advised to write a disciplinary warning, which he did and delivered to the female co-worker. Meinen was terminated in May 2021 and subsequently filed a claim with the Equal Employment Opportunity Commission (EEOC). He then commenced an action in Missouri state court, which Bi-State removed to federal court.The United States District Court for the Eastern District of Missouri dismissed Meinen's claims for failure to state a claim. The court applied the McDonnell Douglas framework to evaluate Meinen’s allegations of discrimination. It found that Meinen failed to show that he was a member of a protected class, was qualified to perform the job, experienced an adverse employment action, and that similarly situated employees outside of the protected class were treated differently. The court also found that the allegations of harassment were not sufficiently severe or pervasive to create an abusive working environment.Upon appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court agreed that Meinen failed to plead sufficient facts to give rise to an inference of causation beyond mere speculation for his retaliation claim. It also concurred with the lower court's application of the McDonnell Douglas framework and its conclusion that Meinen's allegations were insufficient to give rise to an inference of discrimination. Finally, the court agreed that the alleged harassment was not severe or pervasive enough to create a hostile work environment. View "Meinen v. Bi-State Development Agency" on Justia Law

The case involves Noah’s Ark Processors, LLC, and the United Food and Commercial Workers’ Union. After the expiration of their previous collective-bargaining agreement, the parties began negotiations for a new one. The company's representative, however, had no decision-making authority, and the negotiations were brief and ineffective. Frustrated, the union filed charges with the National Labor Relations Board (NLRB). The NLRB filed a petition against Noah’s Ark in federal district court for injunctive relief, which was granted, ordering the company to return to the negotiating table. However, the company declared it was unwilling to negotiate and presented another final offer. The district court issued a contempt finding, and the NLRB determined that Noah’s Ark had failed to bargain in good faith.The parties met seven more times over the next two months, but the negotiations were unsuccessful. Noah’s Ark extended another final offer, which included terms the union had already rejected. The company declared another impasse and made changes unilaterally. The union filed another complaint, and an administrative-law judge found that Noah’s Ark had both bargained in bad faith and prematurely declared an impasse. The NLRB ordered Noah’s Ark to continue negotiating, provide backpay to its employees, reimburse the union for its bargaining expenses, and have its CEO read a remedial notice at an all-employee meeting.The United States Court of Appeals for the Eighth Circuit ruled that substantial evidence supported the NLRB's order and granted enforcement. The court found that Noah’s Ark did not take the negotiations seriously and did not approach the renewed negotiations with an open mind and sincere intention to reach an agreement. The court also agreed with the NLRB's finding that there was no good-faith impasse. The court did not consider Noah’s Ark's objections to the remedies imposed by the NLRB, as the company had not raised these specific objections before the NLRB. View "National Labor Relations Board v. Noah's Ark Processors, LLC" on Justia Law

This case involves Aaron Norgren and his father, Joseph Norgren, who worked for the Minnesota Department of Human Services (DHS). Both men filed Title VII discrimination and retaliation claims against DHS, as well as First Amendment retaliation and compelled speech claims against the DHS Commissioner, Jodi Harpstead. These claims stemmed from the denial of the Norgrens' religious exemption requests to workplace trainings on racism and gender identity. The lower court dismissed their complaints for failure to state a claim.Aaron Norgren argued he was denied a promotion due to his protected activities. The court found that Aaron plausibly established his case and reversed the dismissal of his Title VII discrimination and retaliation claims. However, his First Amendment retaliation claim was dismissed due to insufficient evidence of Commissioner Harpstead's personal involvement in the alleged discriminatory practices.Joseph Norgren's Title VII discrimination claim was dismissed as he did not plausibly allege that he was constructively discharged or that Commissioner Harpstead was personally involved. His First Amendment retaliation claim was also dismissed due to insufficient evidence.Both Norgrens' compelled speech claims were dismissed. The court ruled that while the trainings advanced expressive messages that the Norgrens objected to, there was no evidence they were forced to affirmatively agree with any of the statements in the trainings or were threatened with penalties if they expressed their own viewpoints.Therefore, the court reversed the dismissal of Aaron's Title VII discrimination and retaliation claims and affirmed the dismissal of the remaining claims. View "Norgren v. Minnesota Department of Human Services" on Justia Law