Wages v. Stuart Mgmt. Corp., No. 14-2793 (8th Cir. 2015)Annotate this Case
In 2008, Wages began working as a caretaker for StuartCo, a property management firm, responsible for vacuuming, cleaning, mopping, washing windows, dusting, and snow removal. Wages worked 30 hours per week. Her employee record was unblemished. In 2009, Wages learned she was pregnant. The doctor considered her pregnancy to be high risk. Wages experienced abdominal pain in October. Her doctor directed her not to vacuum or mop and provided her a note for her employer. StuartCo redistributed those duties to other employees and contacted the doctor to verify no other job duties were restricted. In November, Wages’s doctor prohibited snow removal. Wages missed three days of work, in November due to abdominal pain. Her doctor limited her to working no more than 20 hours per week. StuartCo terminated her employment, stating that it was “unable to accommodate the work restrictions provided by your physician.” Wages sued, alleging violations of her rights under the FMLA, Title VII of the Civil Rights Act, the Minnesota Parenting Leave Act (MPLA), and the Minnesota Human Rights Act (MHRA). The Eighth Circuit affirmed summary judgment in favor of Wages on her FMLA entitlement claim and her FMLA retaliation claim, but reversed and remanded for a jury trial on damages.
Court Description: Melloy, Author, with Riley, Chief Judge, and Murphy, Circuit Judge] Civil case - Family Medical Leave Act. Plaintiff established that she had worked for defendant for at least 12 months and that she had provided adequate notice of her need for FMLA leave and thus established her FMLA entitlement claim; further, she established her FMLA-retaliation claim by showing a causal connection between her termination and her assertion of her FMLA rights; however, there were factual disputes regarding the proper amount of damages, and the district court abused its discretion by resolving the matter of damages; remanded for a jury trial on the issue of damages.