Chambers v. The Travelers Companies, Inc., No. 11-1473 (8th Cir. 2012)Annotate this Case
Plaintiff appealed the district court's grant of summary judgment dismissing her claims against her former employer for defamation; breach of a unilateral contract to pay a performance bonus; failure to timely pay wages after discharge in violation of Minn. Stat. 181.13(a); age discrimination; and interference with her rights to employee benefits in violation of section 510 of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1140, and the court's denial of her motion to continue the summary judgment proceedings. The court agreed with the district court that the employer was entitled to the qualified privilege as a matter of law for plaintiff's defamation claims. The court affirmed the district court's dismissal of the breach of contract and unpaid wages claims because all the employer's documents clearly stated that the awarding of bonuses was discretionary. The court further held that the district court properly granted summary judgment dismissing plaintiff's age discrimination claim where plaintiff failed to show that either of her replacements were "sufficiently younger" or that there was a material question of fact regarding pretext; the district court correctly concluded that plaintiff failed to establish a prima facie case of employee benefit plan interference under section 510 of ERISA; and the district court did not abuse its discretion in denying her motion for continuance.