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

Chrylser appealed an adverse jury verdict in favor of plaintiff on a retaliation claim under the Missouri Human Rights Act (MHRA), Mo. Rev. Stat. 213. Plaintiff cross-appealed, claiming that the district court improperly granted a motion for directed verdict on a punitive-damages claim and improperly reduced the attorney's fee award. The court held that the jury instruction on plaintiff's retaliation claim was proper; evidence was sufficient to support the verdict under the MHRA "contributing factor" standard; and the evidence was sufficient to support the jury's economic-damages award. The court affirmed the district court's refusal to submit the punitive damages claim to the jury. Because plaintiff also requested attorney's fees for time spent on post-trial motions and appellate work, however, the court remanded to the district court for consideration of this request, leaving the issue to the district court's discretion. View "Al-Birekdar v. Chrysler Group, LLC" on Justia Law

Plaintiff sued United Systems for sex and disability discrimination after she was terminated. After plaintiff prevailed on both claims, United Systems appealed the district court's denial of its post trial motions for judgment as a matter of law and for remittitur of the mental anguish damages. The court concluded that a legally sufficient basis existed for a reasonable jury to determine that plaintiff had made a showing that she had been discriminated against by her employer. Since the court concluded that the district court did not err in denying United Systems' motion for judgment as a matter of law on plaintiff's sex discrimination claims, the court need not address the denial of the motion on her disability discrimination claims. Considering precedent and the record made in this case, the court could not conclude that the award of $100,000 to plaintiff was monstrous, shocking, or grossly excessive. Accordingly, the district court did not manifestly abuse its discretion in denying the motion for remittitur. View "Hudson v. United Systems of Arkansas, Inc." on Justia Law

Plaintiff filed claims against the county and its officials alleging unlawful suspension and discharge, sex discrimination, retaliation, violation of her procedural and substantive due process rights, and civil conspiracy. The court held that plaintiff's claims were not time barred under Tyler v. University of Arkansas Board of Treasurers; plaintiff had suffered tangible job detriments in the form of her suspension and terminations, but plaintiff failed to show that her rejection of her supervisor's advances caused that detriment; plaintiff could not establish a prima facie case of a hostile work environment because she did not allege sufficiently severe or pervasive conduct; plaintiff's allegations of different treatment were insufficient to establish a prima facie case of discrimination; plaintiff failed to establish the requisite causal relationship to show a violation of the First Amendment in respect to her EEOC charge and her complaints about her supervisor; and plaintiff did not articulate how the county and its officials violated her Fourteenth Amendment rights of due process and equal protection. Accordingly, the court affirmed the district court's grant of summary judgment to the county and its officials. View "Butler v. Crittenden County, Arkansas, et al" on Justia Law

Plaintiff, who is visually impaired, filed suit against BNSF, alleging that BNSF retaliated against him for reporting a safety violation and that BNSF discriminated against him based on his disability. The district court granted summary judgment in favor of BNSF on the whistleblower claim, and the jury found in favor of BNSF on the discrimination claims. The court held that plaintiff's whistleblower claim was untimely and summary judgment should have been granted on that ground; the district court did not err in excluding as irrelevant the evidence of plaintiff's safety complaint; sufficient evidence supported the jury's finding that plaintiff could not perform the essential functions of the locomotive machinist position with or without reasonable accommodation; and the district court did not abuse its discretion in denying plaintiff's motion to set aside the order awarding costs. View "Hohn v. BNSF Railway Co." on Justia Law

Plaintiff sued her former employer, SatCom, alleging violations of the Minnesota Whistleblower Act (MWA), Minn. Stat. 181.932; Minnesota Human Rights Act (MHRA), Minn. Stat. 363A.01-.43; common law of wrongful termination, and Fair Labor Standards Act, 29 U.S.C. 201 et seq. Although plaintiff succeeded in establishing a prima facie case of retaliation where three of her reports constituted a protected activity, the court affirmed the district court's grant of summary judgment in favor of SatCom because SatCom had a legitimate, non-retaliatory reason for terminating plaintiff. Because the district court's McDonnell-Douglas analysis was sufficiently thorough to encompass plaintiff's claims under the Reporting Clause and Opposition Clause of the MWA, plaintiff was not entitled to reversal on this basis. Accordingly, the court affirmed the district court's grant of summary judgment in favor of SatCom. View "Wood v. SatCom Marketing, LLC, et al" on Justia Law

Plaintiff asserted wrongful termination claims against the WCRA, alleging disability discrimination and retaliation in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101-12213; the Minnesota Human Rights Act (MHRA), Minn. Stat. 363A.01-.43; and the Minnesota Whistleblower Act, Minn. Stat. 181.932. On appeal, plaintiff challenged the district court's grant of summary judgment dismissing these claims. The court held that there was no evidence giving rise to an inference that the WCRA terminated her because of her medical condition; plaintiff had no claim of ADA retaliation because she did not engage in protected activity by complaining about disability discrimination; the court doubted that the supervisor's alleged harassment of plaintiff and intimidating management style created a hostile work environment; plaintiff's claim that the WCRA failed to provide reasonable accommodations for her disability failed because she never requested or otherwise adequately informed the WCRA of the need for additional accommodations; plaintiff's Whistleblower Act claim was without merit because there was no evidence plaintiff was terminated because she engaged in statutorily protected conduct; and plaintiff's contention that the district court abused its discretion by excluding certain affidavits was without merit because any error was harmless. Accordingly, the court affirmed the judgment. View "Lenzen v. Workers Compensation Reinsurance Assoc." on Justia Law

Plaintiff, an employee of Cargill, sued under the Family and Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq., asserting FMLA entitlement and retaliation claims. The district court granted Cargill's motion for summary judgment on both claims. The court held that plaintiff had provided insufficient evidence for a reasonable jury to find that she gave Cargill adequate notice under the FMLA; plaintiff's notice requirement was not excused on the basis of extraordinary circumstances; and there were no genuine issues of material fact as to her failure to satisfy her notice obligation under the FMLA and therefore, the district court did not err in dismissing plaintiff's entitlement claim. Further, plaintiff failed to make a prima facie case for FMLA retaliation and the district court did not err in dismissing this claim. View "Bosley v. Cargill Meat Solutions Corp." on Justia Law

A jury found in favor of plaintiff in his employment-discrimination suit under the Missouri Human Rights Act (MHRA), section 213.010 of the Missouri Revised Statutes, against Kaman. Both parties appealed. The court held that plaintiff made a submissible case for punitive damages by providing clear and convincing proof from which a reasonable factfinder could conclude that Kaman acted with evil motive or reckless indifference when it retaliated against him; the $500,000 in punitive damages that the jury awarded plaintiff did not violate due process; the district court did not did not err in refusing to grant a new trial on plaintiff's discrimination and retaliation claims; and the district court did not abuse its discretion in restricting plaintiff's recovery of attorneys' fees. Accordingly, the court affirmed the judgment. View "Trickey v. Kaman Industrial Technologies Corp." on Justia Law

A class of about 1,600 Minnesota delivery drivers employed by Domino's Pizza alleged that, under Minnesota law, a fixed delivery charge that customers paid Domino's was a gratuity wrongfully withheld from them. The court held that the varied context of the pizza delivery transactions made it unreasonable for some customers to construe the delivery charge as a payment for personal services, thereby preventing one-stroke determination of a classwide question. Therefore, the district court abused its discretion by certifying the class. Accordingly, the court reversed the class certification order and remanded for further proceedings. View "Luiken, et al v. Domino's Pizza, LLC" on Justia Law

American Family appealed the district court's order denying its motion for judgment as a matter of law or, in the alternative, for a new trial and awarding defendant attorney's fees pursuant to section 91A.8 of the Iowa Wage Payment Collection Law (IWPCL). The court concluded that the district court did not abuse its discretion in granting defendant's Rule 15(b)(2) motion to amend the pleadings to add the IWPCL claim because the claim was tried with American Family's implied consent and the amendment did not result in prejudice to American Family. The district court did not abuse its discretion in awarding attorney's fees to defendant under the IWPCL. Any error in giving jury Instruction 13A was harmless in light of the subsequently given Instruction No. 14. Accordingly, the court affirmed the judgment of the district court. View "American Family Mutual Ins. Co. v. Hollander" on Justia Law