Oehmke v. Medtronic, Inc., No. 16-1052 (8th Cir. 2016)
Annotate this CasePlaintiff filed suit against Medtronic for disability discrimination and retaliation under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and the Minnesota Human Rights Act (MHRA), Minn. Stat. 363A et seq. The district court granted summary judgment to Medtronic. The court agreed with the district court that there does not exist a strong enough causal connection sufficient as a matter of law to establish a prima facie case of discrimination under the ADA and MHRA. The court also concluded that plaintiff's retaliation claim fails because there is no evidence of a retaliatory motive on Medtronic's part to support a showing of causation even under a mixed-motive standard. In this case, Medtronic had cause to terminate plaintiff due to her performance issues. Plaintiff presented no evidence that any purported statements she made motivated Medtronic's decision to terminate her, and her rejection of Medtronic's proposed settlement agreement is not an activity protected under the ADA. Accordingly, the court affirmed the judgment.
Court Description: Beam, Author, with Gruender and Shepherd, Circuit Judges] Civil case - Employment discrimination. Plaintiff's evidence did not show a strong enough causal connection to create a prima facie case on her claims of disability discrimination under the ADA and the Minnesota Human Rights Act; with respect to plaintiff's retaliation claims, defendant had cause to terminate plaintiff due to her performance issues, and she presented no evidence that statements she made motivated defendant's decision to terminate her; plaintiff's rejection of defendant's proposed settlement is not an activity protected by the ADA.
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