Lovelace v. Washington University School of Medicine, No. 17-3673 (8th Cir. 2019)
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Plaintiff filed suit against her employees, alleging that they unlawfully terminated her in retaliation for exercising her rights under the Family and Medical Leave Act (FMLA) and the Missouri Human Rights Act (MHRA). Plaintiff's husband filed suit for loss of consortium.
The Eighth Circuit held that the district court did not err in granting defendants summary judgment on the FMLA claim, because plaintiff's use of FMLA leave some half-year prior to her termination was insufficient to show her termination was an act of discrimination. The court also held that the district court did not err in granting summary judgment in favor of defendants on the MHRA claim, because plaintiff could not have had a reasonable good faith belief that the conduct she opposed had constituted disability discrimination in violation of the MHRA. For purposes of the MHRA, accusing an employee of racism does not constitute racial discrimination. Furthermore, evidence of general temporary work restrictions, without more, was insufficient to constitute a disability. Finally, the loss of consortium claim was properly dismissed.
Court Description: Smith, Author, with Arnold and Kelly, Circuit Judges] Civil case - Family and Medical Leave Act. Plaintiff's intervening conduct - refusal to engage her supervisors in performance evaluation and her subsequent outburst with a co-worker - ended any connection there might have been between her use of FMLA leave and her eventual termination; for purposes of the Missouri Human Rights Act, accusing an employee of racism does not constitute racial discrimination, and plaintiff had no legitimate basis for believing she was discriminated against on the basis of her race when her supervisor asked her whether she had made a comment based on a co-worker's race; as such, she could not have a reasonable good faith belief that the conduct she opposed constituted racial discrimination in violation of the MHRA, and her MHRA racial discrimination retaliation claim fails; evidence of general temporary work restrictions, without more, is insufficient to constitute a disability, and plaintiff's disability discrimination claim fails; plaintiff's husband's claim for loss of consortium is a derivative spousal claim, and it was properly dismissed upon the grant of defendants' motion for summary judgment on plaintiff's ADA and MHRA claims.
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