Stewart v. Rise, Inc., No. 13-3579 (8th Cir. 2015)
Annotate this CaseIn 2007-2012, Stewart was supervisor of a branch office for Rise, a welfare-services non-profit entity that obtained funding from a Minnesota welfare program, "Pathways." Stewart supervised counselors who directly assisted clients. Stewart's performance was measured in part by the relative workforce participation rate for her office's clients compared to clients of other Pathways organizations. During Stewart's tenure, other offices closed, a state government shut-down occurred, and workloads from different offices were consolidated, without a commensurate increase in staffing. When Stewart began working at Rise, the workforce participation rate was at a generally acceptable level. By the time she was terminated, her office’s performance had deteriorated. Stewart's predecessor and successor were, like Stewart, American-born African-American women. Stewart claimed that male, Somali-born subordinates created a hostile work environment through sexist, racist, and nationalist comments and through physical violence and intimidation, and that her supervisors ignored her complaints, denied her the authority to terminate the offending employees, allowed the hostile environment to persist, and eventually terminated her employment as an act of discrimination and retaliation. The district court granted summary judgment for Rise. The Eighth Circuit reversed and remand as to the hostile work environment claim but otherwise affirmed.
Court Description: Melloy, Author, with Murphy and Benton, Circuit Judges] Civil case - Employment discrimination. Plaintiff failed to establish a prima facie case of discriminatory termination as there was little support for an inference that discrimination by the decision-makers motivated the termination; with respect to plaintiff's hostile-work-environment claim, the district court erred in granting the employer's motion for summary judgment as a jury could determine that the comments at issue were part of a consistent pattern of verbal abuse based on sex, race or national origin and were tied to overt acts of intimidation, violence or insubordination which were reported to her supervisors; the evidence showed plaintiff's supervisors had decided to terminate her before she filed an EEOC complaint and her retaliation claim failed; remanded for further proceedings on the hostil-work-environment claim.
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