Esperance v. Vilsack

CourtDistrict Court, D. South Dakota
DecidedSeptember 3, 2024
Docket5:20-cv-05055
StatusUnknown

This text of Esperance v. Vilsack (Esperance v. Vilsack) is published on Counsel Stack Legal Research, covering District Court, D. South Dakota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Esperance v. Vilsack, (D.S.D. 2024).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF SOUTH DAKOTA WESTERN DIVISION

RUTH ESPERANCE, 5:20-CV-05055-LLP Plaintiff, vs. MEMORANDUM OPINION AND ORDER ON POST-TRIAL MOTIONS THOMAS J. VILSACK, Secretary of Agriculture, U.S. Department of Agriculture, Defendant. This Title VI gender discrimination case was tried to a jury beginning on September 18, 2023. The jury returned a verdict for Plaintiff and awarded damages in the amount of $400,000 on September 23, 2023. Defendant has renewed his motion for judgment as a matter of law pursuant to Rule 50(b) of the Federal Rules of Civil Procedure. (Doc. 122.) In the alternative, Defendant moves for a new trial or remittitur under Rule 59. Additionally, Defendant moves to amend the judgment to conform to the statutory cap of $300,000 for compensatory damages pursuant to 42 U.S.C. § 198la. Plaintiff agrees that the damage award must conform to the $300,000 statutory cap under Title VI, but Plaintiff opposes Defendant’s motions for judgment as a matter of law and new trial or remittitur. (Doc. 131.) The background is set forth in the Court’s previous Memorandum Opinion and Order and it will not be repeated here. (Doc. 91.) □ DISCUSSION □ I. Motion for Judgment as a Matter of Law A. Standard of Review “Rule 50(b) provides for post-trial renewal of a Rule 50(a) trial motion for judgment as a matter of law.” Nassar v. Jackson, 779 F.3d 547, 551 (8th Cir. 2015). “Under Rule 50, if the court finds that a reasonable jury would not have a legally sufficient evidentiary basis to find for a party on an issue, the court may grant a motion for judgment as a matter of law against the party.” Howard v. Mo. Bone & Joint Ctr., Inc., 615 F.3d 991, 995 (8th Cir. 2010) (quoting Fed. R. Civ. P.

50(a)) (internal quotation marks omitted). The court should review all of the evidence in the record and must draw all reasonable inferences in favor of the nonmoving party. Reeves v. Sanderson Plumbing Products, 530 U.S. 133, 148-151 (2000). “Credibility determinations, the weighing of the evidence, and the drawing of legitimate inferences from the facts are jury functions, not those of judge.” Jd. at 150. “[A]lthough the court should review the record as a whole, it must disregard all evidence favorable to the moving party that the jury is not required to believe.” Jd. at 151. Though courts typically analyze Title VII discrimination cases under the burden-shifting analysis of McDonnell Douglas at the summary judgment stage, after all the evidence has been presented at trial, the inquiry should focus on the ultimate issue of intentional discrimination, not on any particular step in the McDonnell Douglas framework. See Weber v. Strippit, Inc., 186 F 3d 907, 917-18 (8th Cir. 1999); Gilkerson v. Toastmaster, Inc., 770 F.2d 133, 135 (8th Cir. 1985). “Title VII has been interpreted to require only that, in addition to the first three elements of a prima facie case, the plaintiff demonstrate that his or her discharge occurred in ‘circumstances which allow the court to infer unlawful discrimination.’” Walker v. St. Anthony’s Medical Center, 881 F.2d 554, 558 (8th Cir. 1989) (quoting Craik v. Minnesota State University Board, 731 F.2d 465, 469 (8th Cir.1984)).! . Under Title VII, “an unlawful employment practice is established when the complaining party demonstrates that race, color, religion, sex, or national origin was a motivating factor for any employment practice, even though other factors also motivated the practice.” 42 U.S.C. § 2000e- 2(m) (emphasis added). Therefore, in order to prove intentional discrimination based on sex, a plaintiff is not required to show gender was the sole reason for the employer’s adverse action. Rather, a plaintiff need only demonstrate that gender was at least one of the motivating factors for the decision. See generally University of Texas Southwestern Medical Center v. Nassar, 570 U.S. 338 (2013) (discussing Title VII’s “motivating-factor” standard for race, color, religion, sex, and national origin discrimination).

A prima facie case of discrimination requires a plaintiff to show she: “(1) is a member of a protected group; (2) was meeting the legitimate expectations of the employer; (3) suffered an adverse employment action; and (4) suffered under circumstances permitting an inference of discrimination.” Davis v. Jefferson Hosp. Ass’n, 685 F.3d 675, 681 (8th Cir. 2012). The first three elements were not disputed at trial in this case.

Thus, the ultimate question for purposes of Defendant’s motion for judgment as a matter of law is whether there is sufficient evidence to support the jury’s finding that Plaintiff's gender was a motivating factor in Defendant’s decision to transfer Plaintiff out of her ranger position. B. Discussion . Plaintiff did not present direct evidence of discriminatory intent in this case. Instead, Plaintiff relied on indirect evidence. Compared to direct evidence, indirect evidence provides a weaker causal link between the employer’s alleged discriminatory intent and the adverse action, but it may nonetheless establish discrimination. Robinson v. Am. Red Cross, 753 F.3d 749, 756 (8th Cir. 2014). The Court will examine whether Plaintiff presented sufficient evidence permitting the jury to infer that discrimination was a motivating factor in Defendant’s decision to remove Plaintiff from the ranger position. 1. Evidence Permitting Inference of Discrimination The jury was instructed that “the plaintiff's gender was a ‘motivating factor’ if the plaintiff's gender played a part or a role in the defendant’s decision to reassign the plaintiff. However, the plaintiff's gender need not have been the only reason for the defendant’s decision to reassign plaintiff.”? (Doc. 100, Instruction No. 9.) Plaintiff testified that Mark Van Every gave more favorable treatment to her male coworkers. (TT, Doc. 112, p. 315.) Plaintiff described how Mr. Van Every would dismiss her input on natural resource management topics during meetings, but he would praise a male co- worker if he brought up the same idea. (/d., p. 316.) Plaintiff discussed a time where Mr. Van Every asked her male colleague to present information on one of Plaintiff's own projects called Star of the West. The practice was to have the ranger in charge of the program present the information, so Plaintiff should have been the one to present on Star of the West instead of the male ranger. Mr. Van Every never did that to a male. (dd., pp. 319-20.) Plaintiff also testified that she applied for a temporary deputy forest supervisor job under Mr. Van Every, but a male colleague was selected. (/d., pp. 326-28.) Defendant refers to Plaintiff’s testimony as “self-serving,” and argues that Plaintiff's own testimony about treatment by Mr. Van Every, standing alone, is insufficient to establish

2 This instruction is based on the Eighth Circuit’s Model Civil Jury Instruction 5.21.

discrimination. But the credibility to be given a witness and the weight to be given her testimony is decided by the jury. See, e.g. United States v.

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Bluebook (online)
Esperance v. Vilsack, Counsel Stack Legal Research, https://law.counselstack.com/opinion/esperance-v-vilsack-sdd-2024.