Marez v. Saint-Gobain Containers, Inc., No. 11-2356 (8th Cir. 2012)
Annotate this CaseKathleen Marez sued her former employer, Saint-Gobain Containers, Inc. for unlawful termination. Marez claimed that Saint-Gobain retaliated against her in violation of the family Medical Leave Act (FMLA) and that Saint-Gobain committed gender discrimination in violation of the Missouri Human Rights Act (MHRA). A jury returned a verdict in Marez's favor on the FMLA claim and in Saint-Gobain's favor on the gender discrimination claim. The district court awarded Marez liquidated damages and part of her requested attorneys' fees. The Eighth Circuit Court of Appeals affirmed, holding (1) there was sufficient evidence to support the jury's verdict in Marez's favor; (2) the district court did not abuse its discretion in awarding liquidated damages, as Saint-Gobain was liable for employment discrimination under the cat's-paw theory of liability, and liquidated damages may be awarded in eligible FMLA cases premised on cat's-paw liability; and (3) the district court did not abuse its discretion in its award of attorneys' fees.
Court Description: Civil case - Employment discrimination. Evidence was sufficient to support the jury's verdict in favor of plaintiff on her claim of Family Medical Leave Act discrimination, where she was terminated 48 hours after notice of protected activity and her other evidence showed defendant had not terminated other employees for the grounds given for her termination; award of liquidated damages may be awarded in eligible FMLA cases premised on "cat's-paw" liability; district court did not abuse its discretion in reducing plaintiff's requested attorneys' fees based on her limited success.
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