Sellers v. Deere & Co., No. 14-2244 (8th Cir. 2015)
Annotate this CaseSellers, a Deere employee for more than 30 years, sued Deere and his supervisor, alleging age discrimination under the Age Discrimination in Employment Act, 29 U.S.C. 621, and the Iowa Civil Rights Act; disability discrimination under the Americans with Disabilities Act), 42 U.S.C. 12101; retaliation under the ADEA, ICRA, and ADA; and harassment because of his age and disability. The district court granted defendants summary judgment. The Eighth Circuit affirmed, finding that Sellers did not suffer an adverse employment action when his title and duties changed during a company-wide personnel reorganization. Incidents identified by Sellers may have been “rude or unpleasant,” but they were not “severe enough to affect the terms, conditions, or privileges of his employment.”
Court Description: Riley, Author, with Colloton and Kelly, Circuit Judges] Civil case - Employment discrimination. Plaintiff did not mention defendant's company-wide personnel reorganization or make any claim that he had been demoted in his complaint to the EEOC and could not allege that he was demoted under the reorganization; even if the issue was preserved for review, the claim that implementation of the reorganization was an adverse employment action was meritless; the addition of job duties did not constitute a material change in the terms and conditions of employment and was not an adverse employment action; the lack of an adverse employment action was fatal to plaintiff's age discrimination claim; the conduct which plaintiff complained of was not sufficiently severe to support a hostile work environment claim.
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