Barcomb v. General Motors LLC, No. 19-1350 (8th Cir. 2020)
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Plaintiff filed suit alleging that he was wrongfully fired from GM under both federal and state law because he reported safety issues with the manufacturing process at the plant in Wentzville, Arkansas. The district court granted summary judgment in favor of GM on the retaliatory discharge claim under section 31307 of the Moving Ahead for Progress in the 21st Century Act (MAP-21) and granted costs to GM under Federal Rule of Civil Procedure 54(d).
The Eighth Circuit held that plaintiff's complaints about the quality control processes in a manufacturing plant are not information related to a motor vehicle defect, and thus he did not engage in protected activity under MAP-21. The court also held that the district court did not err in deciding to grant costs, and did not abuse its discretion by awarding both the costs of stenographic and video deposition services. The court reversed the district court's award of $76.50 for the postage and shipping costs, and otherwise affirmed the judgment.
Court Description: [Kobes, Author, with Melloy and Erickson, Circuit Judges] Civil case - Employment law. In an action alleging GM violated the Moving Ahead for Progress in the 21st Century Act by retaliating against plaintiff for alerting management to motor vehicle defects falsely reported and/or confirmed as repaired, the district court did not err in granting GM summary judgment as plaintiff's complaint about the quality control processes in a manufacturing plant are not information related to a motor vehicle defect and he did not, therefore, engage in activity protected under the statute; no error in awarding GM's costs (with the exception of some postage and shipping costs GM concedes were erroneously awarded). Judge Melloy, concurring in part and dissenting in part.
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