Brooks v. Midwest Heart Group, No. 10-3712 (8th Cir. 2011)
Annotate this CasePlaintiff appealed the dismissal of her action against a former employer alleging race, sex, and age discrimination and retaliation in violation of Title VII. The district court concluded that plaintiff had not filed a charge of discrimination with the EEOC within 300 days of her termination, as required to exhaust her claim, and therefore dismissed the case for failure to state a claim. The court held that because the district court rested its factual conclusions on matters outside the pleadings, it erred by failing to convert the employer's motion into one for summary judgment under Federal Rule of Civil Procedure 56. This error did not prejudice plaintiff with regard to her claims of age discrimination and retaliation, so the court affirmed the district court's dismissal in this respect. The court held that because the error was prejudicial with respect to the remaining claims of race and sex discrimination, however, the court reversed the district court's dismissal and remanded for further proceedings.
Court Description: Civil case - Employment Discrimination. Because it relied on matters outside the record in dismissing the action for failure to state a claim, the district court erred in failing to convert the motion to dismiss into a motion for summary judgment; while the error did not prejudice plaintiff with respect to her claims for age discrimination and retaliation, it did prejudice her with regard to her remaining claims for race and sex discrimination, and the dismissal of those claims is reversed; the case is remanded for further proceedings.
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