Quinn v. St. Louis County, No. 10-3332 (8th Cir. 2011)
Annotate this CasePlaintiff sued her employer under the Minnesota Human Rights Act (MHRA), Minn. Stat. 363A.01-43, and the Family Medical Leave Act (FMLA), 29 U.S.C. 2601-54, and asserted other state common law claims including breach of employment contract. Plaintiff subsequently appealed the dismissal of her breach of contract claim with prejudice, the denials of her motions for leave to amend her complaint, the denial of her motion for consideration, and the adverse grant of her MHRA and FMLA claims by the district court. The court did not reach the merits of plaintiff's arguments because any error with respect to the dismissal of the breach of employment contract claim was harmless where plaintiff resigned from her employment with the county and failed to generate a genuine issue of fact as to constructive discharge in the context of her MHRA reprisal claim. The court also held that because plaintiff failed to generate an issue of fact as to whether she suffered a materially adverse employment action, summary judgment was appropriate as to her MHRA retaliation claim. The court further held that summary judgment was properly granted on plaintiff's FMLA interference claim where plaintiff did not contest the district court's finding that she received the full twelve weeks of FMLA leave to which she was entitled each year she requested it. The court finally held that summary judgment was properly granted on plaintiff's FMLA retaliation claim where she failed to generate an issue of fact as to whether she suffered an adverse employment action.
Court Description: Civil case - employment discrimination. Any error with respect to dismissing plaintiff's breach of employment contract claim was harmless because she resigned and failed to establish constructive discharge; plaintiff failed to establish a claim of retaliation under the Minnesota Human Rights Act because she failed to show she suffered a materially adverse employment action; plaintiff failed to show she was denied employee entitlements under the Family Medical Leave Act, and the district court did not err in granting the employer summary judgment on plaintiff's FMLA interference claim; since plaintiff failed to show she suffered an adverse employment action, her FMLA retaliation claim failed.
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