Doucette v. Morrison County, Minnesota, No. 13-2424 (8th Cir. 2014)
Annotate this CasePlaintiff filed suit under the Minnesota Human Rights Act (MHRA), Minn. Stat. 363A et seq., alleging that the County discriminated her based on her sex and her age when they terminated her employment. Plaintiff also claimed that the County retaliated against her after she took leave under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601. On appeal, plaintiff challenged the district court's grant of summary judgment on her MHRA discrimination claims. The court concluded that the County offered a non-discriminatory, legitimate justification for its conduct - plaintiff was terminated based on her repeated record-keeping errors - and plaintiff failed to show that the County's reasons for firing her was pretextual. Therefore, the court affirmed the district court's grant of summary judgment on plaintiff's sex discrimination claim. Further, plaintiff failed to present sufficient evidence to create a genuine issue of material fact as to her sex-plus age discrimination claim where her two male co-workers of comparable age did not engage in sufficiently similar misconduct or have a similar disciplinary history. Accordingly, the court affirmed the judgment of the district court.
Court Description: Civil case - Employment discrimination. With respect to plaintiff's claim that she was fired based on her gender, assuming she made a prima facie case of discrimination, she failed to show the employer's legitimate, non-discriminatory job performance grounds for her discharge were a pretext for sex discrimination; with respect to plaintiff's sex-plus-age discrimination claim under the Minnesota Human Rights Act, plaintiff could not establish that discriminatory intent motivated her termination since the two male co-workers of comparable age she used to support the claim did not engage in sufficiently similar misconduct or have a similar disciplinary history.
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