Thomas v. Heartland Employment Servs., LLC, No. 14-1349 (8th Cir. 2015)
Annotate this CaseHeartland employed Thomas as an account liaison from May 2010 until she was terminated in June 2011, at age 53. Thomas claims that Hagen, an administrator for Heartland, had commented “that older people didn’t work as fast or were as productive as younger people,” and about having ‘fresh blood, younger employees.” Hagen referred to Thomas as “the old short blond girl,” and, after Thomas’s discharge,told a Heartland client that “he likes to keep himself surrounded with young people.” A Heartland human resources manager testified that Hagen was “an indirect supervisor” of the account liaison personnel. Duncan, Heartland’s regional manager, had audited three weeks of Thomas’s mileage claims and determined that Thomas had falsified her reimbursement claims. Thomas maintains she responded that she kept records that would explain discrepancies between the claimed mileage and the weekly call plans, but that Hagen dismissed her response by stating that termination “was a decision they had made.” In her suit, alleging violation of the Missouri Human Rights Act, the court granted the defendants summary judgment. The Eighth Circuit reversed, finding that there was a genuine issue of material fact as to whether age was a contributing factor in Thomas’s discharge by Heartland and Hagen.
Court Description: Colloton, Author, with Loken and Smith, Circuit Judges] Civil case - Employment discrimination. There was a genuine issue of material fact as to whether age was a contributing factor in plaintiff's discharge and the district court erred in granting defendants' motion for summary judgment on plaintiff's age claim under the Missouri Human Rights Act; a jury could reasonably infer that defendant Hagen was a decision-maker or closely involved in the decision to terminate plaintiff; Hagen's age-related comments were sufficiently related to plaintiff and to the decisional process to constitute direct evidence of discrimination; as a result, a reasonable jury could infer that Hagen affirmed and took part in the discharge decision, that he was motivated by age-based animus and that his bias was a contributing factor in the adverse employment action.
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