Barnhardt v. Open Harvest Cooperative, No. 13-2254 (8th Cir. 2014)
Annotate this CasePlaintiff appealed the district court's entry of summary judgment in favor of Open Harvest on plaintiff's claim alleging a violation of section 510 of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1140. Because plaintiff has not identified direct evidence of a specific intent to interfere with her ERISA benefits, the court must analyze her claim under the McDonnell Douglas burden-shifting framework. In this case, Open Harvest articulated a legitimate, non-discriminatory justification for its failure to pay the August policy premium. Under the McDonnell Douglas framework, the burden shifted back to plaintiff to show a genuine dispute whether Open Harvest's justification was pretextual. Plaintiff failed to show a genuine dispute whether Open Harvest terminated her employment with a specific intent to interfere with her ERISA benefits. Accordingly, the court affirmed the district court's grant of summary judgment in favor of Open Harvest.
Court Description: Civil case - ERISA. Plaintiff failed to identify any direct evidence that she was terminated with intent to interfere with her ERISA benefits; applying the McDonnell Douglas burden-shifting analysis, the employer articulated legitimate, non-discriminatory performance-related ground for failing to pay a premium to the benefits provider ,and plaintiff failed to show this ground was a pretext for intent to interfere with her ERISA benefits.
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