Thompson v. Kanabec County, No. 19-1456 (8th Cir. 2020)
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The Eighth Circuit affirmed the district court's grant of summary judgment to the County on plaintiff's claim of interference with her rights under the Family Medical Leave Act (FMLA) and retaliation against her for asserting those rights. Plaintiff's claims arose when she was put on administrative leave following an investigation into her involvement in her husband's sexual abuse of their children. The court held that plaintiff failed to show any prejudice from the County's delay in acting on her FMLA request or its failure to give her notice of her FMLA rights. The court rejected the FMLA interference claim, holding that plaintiff was neither asked to nor required to complete work-related tasks while on leave. Rather, the activities plaintiff was asked to do related to the underlying child-protection investigation, her FMLA request, and her employment status.
The court also held that the County was entitled to summary judgment on plaintiff's discrimination claim where the undisputed sequence of events does not demonstrate a causal link between her FMLA request and the Board's decision to proceed with a meeting regarding whether to terminate her employment. In this case, the Board's actions were based on the maltreatment determination. Finally, the court held that the district court did not err in declining to exercise supplemental jurisdiction over the state law claims, and the district court did not abuse its discretion in awarding costs to the County.
Court Description: [Erickson, Author, with Grasz and Kobes, Circuit Judges] Civil case - Family and Medical Leave Act. Plaintiff showed no prejudice from the County's delay in acting on her FMLA request or its failure to give her notice of her FMLA rights as she was on personal leave when she requested FMLA and remained on leave until she resigned; the activities plaintiff was asked to do related to the underlying child-protection investigation, her FMLA request and her employment status, and the County's request that she assist with these matters did not constitute interference with plaintiff's FMLA rights; plaintiff failed to provide direct evidence of FMLA bias from a decision maker; applying the McDonnell Douglas analysis to her indirect evidence of FMLA discrimination, plaintiff failed to establish a materially adverse employment action, including constructive discharge, or that there was causal connection between her actions and the adverse employment action; as she did not establish a prima facie case of FMLA discrimination, the district court did not err in granting defendants summary judgment on this claim; the district court did not err in declining to exercise supplemental jurisdiction over plaintiff's state law claims; the district court did not abuse its discretion in awarding costs to the County as it prevailed on all plaintiff's federal claims and the court dismissed plaintiff's state law claims.
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