Mahler v. First Dakota Title Limited Partnership, No. 18-1632 (8th Cir. 2019)
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The Eighth Circuit affirmed the district court's grant of summary judgment to the employer in an action brought by plaintiff, alleging claims under Title VII of the Civil Rights Act and the Iowa Civil Rights Act for retaliation, discrimination, and hostile work environment.
The court held that summary judgment on the retaliation claim was proper under the McDonnell Douglas burden-shifting framework. Even assuming plaintiff established a prima facie showing of retaliation, substantial evidence in the record supported the employer's proffered reason for its termination of plaintiff: she repeatedly micromanaged and interfered with other employees. Therefore, plaintiff failed to show that the employer's reason for her termination was pretextual. The court also held that plaintiff failed to establish a prima facie case of hostile work environment based on sex, because her actions demonstrated that she did not personally experience offensive or unwelcome harassment. Furthermore, plaintiff's claim for hostile work environment based on a protected activity failed, because she failed to show that she experienced harassment so severe or pervasive as to constitute a materially adverse action. Finally, plaintiff waived her discrimination claims.
Court Description: Benton, Author, with Wollman and Grasz, Circuit Judges] Civil case - Employment discrimination. Plaintiff failed to produce direct evidence of retaliation and the case was properly analyzed under the McDonnell Douglas burden-shifting framework; assuming plaintiff made a prima facie case of retaliation, plaintiff failed to establish defendant's stated grounds were pretexts; plaintiff failed to establish a prima facie case of hostile work environment based on sex; plaintiff could not show she experienced harassment so severe or pervasive so as to constitute a materially adverse action and her claim for hostile work environment for engaging in protected activity failed; plaintiff waived her claim for discrimination based on gender.
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