Button v. Dakota, Minnesota & Eastern Railroad Corp., No. 19-1398 (8th Cir. 2020)
Annotate this Case
Plaintiff filed suit against the railroad under the Missouri Human Rights Act (MHRA) and the Family and Medical Leave Act (FMLA), alleging that the railroad discriminated against her on the basis of her gender and her use of FMLA leave when it terminated her. The railroad maintains that plaintiff was terminated as part of a reduction in force (RIF) without discriminatory intent.
The Eighth Circuit affirmed the district court's grant of summary judgment to the railroad, holding that the affidavits that the district court relied on were not sham affidavits; plaintiff failed to present any evidence to create a genuine dispute of material fact that her gender was a contributing factor in her termination; the RIF was legitimate and plaintiff failed to demonstrate evidence showing that her gender was a contributing factor in her termination; and thus the district court properly granted the railroad summary judgment on plaintiff's MHRA gender-discrimination claim. Because plaintiff does not offer any direct evidence that the railroad terminated her in the RIF for exercising her FMLA rights, the court analyzed her claim under the McDonnell Douglas burden-shifting framework. In this case, the railroad proffered a legitimate, nondiscriminatory reason for terminating plaintiff and she failed to show that the stated reason was a pretext for FMLA discrimination.
Court Description: [Smith, Author, with Colloton and Stras, Circuit Judges] Civil case - Family Medical Leave Act. Plaintiff alleged she was terminated on the basis of her gender, in violation of the Missouri Human Rights Act, and for exercising her FMLA rights; argument that the district court improperly relied on sham affidavits from defendant's employees rejected; there was no direct evidence of discrimination based on gender; defendant's reduction-in-force was a legitimate RIF; there was no evidence that plaintiff's gender was a contributing factor in her termination; there was no direct evidence that defendant terminated plaintiff in the RIF for exercising her FMLA rights and her claim would be analyzed under the McDonnell Douglas framework; under that analysis, defendant presented a legitimate, non-discriminatory reason to terminate plaintiff and she failed to show the stated reason was a pretext for FMLA discrimination.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.