Taylor v. LSI CORP. OF AMERICA

781 N.W.2d 912, 2010 Minn. App. LEXIS 59, 109 Fair Empl. Prac. Cas. (BNA) 159, 2010 WL 1657990
CourtCourt of Appeals of Minnesota
DecidedApril 27, 2010
DocketA09-1410
StatusPublished
Cited by4 cases

This text of 781 N.W.2d 912 (Taylor v. LSI CORP. OF AMERICA) is published on Counsel Stack Legal Research, covering Court of Appeals of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Taylor v. LSI CORP. OF AMERICA, 781 N.W.2d 912, 2010 Minn. App. LEXIS 59, 109 Fair Empl. Prac. Cas. (BNA) 159, 2010 WL 1657990 (Mich. Ct. App. 2010).

Opinion

OPINION

BJORKMAN, Judge.

Appellant challenges the district court’s grant of summary judgment based on her failure to present material facts demonstrating that her termination from LSI constituted a direct attack on the institution of marriage. Because the Minnesota Human Rights Act more broadly prohibits discrimination based on the identity and situation of an employee’s spouse, we reverse and remand.

FACTS

Respondent LSI Corporation of America (LSI) hired appellant LeAnn Taylor in 1988 as a receptionist/secretary. LSI is a Minnesota corporation that manufactures cabinetry and casework primarily for schools and health-care facilities. In 1999, when LSI’s founder sold the company to Sagus International (Sagus), LSI became a wholly owned subsidiary of Sagus.

In September 1999, Gary Taylor joined LSI as its president. In January 2000, he began dating appellant. One year later, appellant was promoted to sales and marketing coordinator. At the time of her promotion, she was engaged to marry Taylor. In her new position, appellant was to report to LSI’s head of marketing. But it does not appear that LSI’s head of marketing and appellant even discussed her job functions. Appellant and Taylor married in 2001.

In 2006, Daryl Rosser, the CEO of Sa-gus, became concerned about LSI’s performance. Rosser had fielded numerous complaints from LSI’s customers and suppliers. He determined that LSI was missing customer delivery dates, its margin performance did not meet expectations, and employee morale was poor. Sagus conducted a formal review of LSI’s management structure, and ultimately terminated or accepted resignations from 6 of the 25 management employees. Appellant and Taylor are two of the employees who either resigned or were terminated.

Appellant alleges that prior to her termination, Rosser and Taylor had a conversation in which they discussed appellant’s continued employment with LSI. Appellant asserts that Rosser asked Taylor if he wanted to announce appellant’s departure at the same time he announced his own. When Taylor responded that appellant had her own rights, and he would not get involved, Rosser told him that since Taylor was leaving LSI, “it would probably be uncomfortable or awkward for [appellant] to stay.”

Appellant also alleges that, at a separate meeting, Rosser told her directly that because Taylor was leaving LSI, “he probably will be [relocating], which means you’ll be relocating as well. So we just decided to eliminate your position.”

Rosser disputes appellant’s version of these events, asserting that her termination was based solely on considerations of the available workload and LSI’s financial situation. Rosser denies telling anyone that appellant was fired because of her husband. Rosser acknowledged that he did discuss appellant’s employment status with Taylor, but only asked Taylor whether appellant, like Taylor, would welcome the opportunity to resign rather than be terminated in order to “save face.”

Appellant’s employment ended on August 18, 2006, and her position has not been filled. Her job functions were transferred to another employee, who is also married. Taylor’s resignation was effective a few weeks later.

Appellant commenced this action alleging marital-status discrimination in viola *915 tion of the Minnesota Human Rights Act (MHRA), Minn.Stat. § 363A.08, subd. 2 (2006). Appellant claims that she was terminated solely because her husband’s employment at LSI was ending. LSI moved for summary judgment on the basis that appellant did not come forward with evidence showing that her termination was “directed at her marital status itself.” The district court granted LSI’s motion. This appeal follows.

ISSUES

I. Did the district court err in determining that marital-status discrimination under the MHRA requires a direct attack on the institution of marriage?

II. Did appellant present sufficient evidence to prove a prima facie case of marital-status discrimination?

ANALYSIS

“On an appeal from summary judgment, we ask two questions: (1) whether there are any genuine issues of material fact and (2) whether the [district] court[ ] erred in [its] application of the law.” State by Cooper v. French, 460 N.W.2d 2, 4 (Minn.1990). “We review de novo whether a genuine issue of material fact exists” and “whether the district court erred in its application of the law.” STAR Ctrs., Inc. v. Faegre & Benson, L.L.P., 644 N.W.2d 72, 77 (Minn.2002). This court “must view the evidence in the light most favorable to the party against whom judgment was granted.” Fabio v. Bellomo, 504 N.W.2d 758, 761 (Minn.1993).

Summary judgment is appropriate when the “record reflects a complete lack of proof on an essential element of the plaintiffs claim.” Lubbers v. Anderson, 539 N.W.2d 398, 401 (Minn.1995). As to a claim of unlawful employment discrimination, summary judgment is appropriate if the employee (1) fails to present a prima facie case of discrimination, or (2) having established a prima facie case, fails to show a genuine fact issue as to whether the “employer’s proffered nondiscriminatory reasons for its employment decision were pretextual.” Albertson v. FMC Corp., 437 N.W.2d 113, 116 (Minn.App.1989).

I.

The MHRA provides that it is an unfair employment practice to terminate an employee based on marital status. Minn. Stat. § 363A.08, subd. 2. The legislature did not initially define marital status under the MHRA. In Kraft, Inc. v. State by Wilson, 284 N.W.2d 386, 388 (Minn.1979), the supreme court broadly defined marital status, concluding that an employer violated the MHRA by preventing a part-time employee from applying for a full-time position solely because the applicant was married to another full-time Kraft employee. The Kraft court expressly rejected the argument that the identity or situation of an employee’s spouse falls outside of the definition of marital status. 284 N.W.2d at 388.

The supreme court declined to further extend the definition of marital status to protect a potential employee from discrimination based on her spouse’s political views or associations. Cybyske v. Indep. Sch. Dist. No. 196, 347 N.W.2d 256, 261 (Minn.1984), ce rt. denied, 469 U.S. 933, 105 S.Ct. 330, 83 L.Ed.2d 266 (1984). The Cybyske court distinguished Kraft,

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781 N.W.2d 912, 2010 Minn. App. LEXIS 59, 109 Fair Empl. Prac. Cas. (BNA) 159, 2010 WL 1657990, Counsel Stack Legal Research, https://law.counselstack.com/opinion/taylor-v-lsi-corp-of-america-minnctapp-2010.