Norgren v. Minnesota Department of Human Services, No. 23-1207 (8th Cir. 2024)
Annotate this Case
This case involves Aaron Norgren and his father, Joseph Norgren, who worked for the Minnesota Department of Human Services (DHS). Both men filed Title VII discrimination and retaliation claims against DHS, as well as First Amendment retaliation and compelled speech claims against the DHS Commissioner, Jodi Harpstead. These claims stemmed from the denial of the Norgrens' religious exemption requests to workplace trainings on racism and gender identity. The lower court dismissed their complaints for failure to state a claim.
Aaron Norgren argued he was denied a promotion due to his protected activities. The court found that Aaron plausibly established his case and reversed the dismissal of his Title VII discrimination and retaliation claims. However, his First Amendment retaliation claim was dismissed due to insufficient evidence of Commissioner Harpstead's personal involvement in the alleged discriminatory practices.
Joseph Norgren's Title VII discrimination claim was dismissed as he did not plausibly allege that he was constructively discharged or that Commissioner Harpstead was personally involved. His First Amendment retaliation claim was also dismissed due to insufficient evidence.
Both Norgrens' compelled speech claims were dismissed. The court ruled that while the trainings advanced expressive messages that the Norgrens objected to, there was no evidence they were forced to affirmatively agree with any of the statements in the trainings or were threatened with penalties if they expressed their own viewpoints.
Therefore, the court reversed the dismissal of Aaron's Title VII discrimination and retaliation claims and affirmed the dismissal of the remaining claims.
Court Description: [Erickson, Author, with Melloy and Stras, Circuit Judges] Civil case - Civil rights. Plaintiffs, father and son, brought Title VII discrimination and retaliation claims against the Minnesota Department of Human Services, their employer, and Section 1983 retaliation and compelled speech claims against the Department's Commissioner, arising out of the denial of their religious exemption requests to workplace training on racism and gender identity; the district court dismissed the complaints for failure to state a claim; the son, Aaron, plausibly pled that he was denied a promotion because of his protected activities, and the dismissal of his Title VII discrimination and retaliation claims is reversed; the district court's dismissal of the remaining claims is affirmed.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.