Michelle Brandt v. City of Cedar Falls, No. 21-2537 (8th Cir. 2022)
Annotate this Case
Plaintiff a former part-time employee of the City of Cedar Falls, brought an action against the City of Cedar Falls and certain city officials after her 2018 termination, alleging interference with and retaliation for the exercise of her rights under the Family and Medical Leave Act (FMLA) and claims of age discrimination, disability discrimination, hostile work environment, and retaliation under the Iowa Civil Rights Act (ICRA). The district court granted summary judgment in favor of Defendants on all of Plaintiff’s claims, and she appealed.
The Eighth Circuit affirmed. The court explained that it need not consider the substantive elements of the claim because Plaintiff has failed to demonstrate that she sustained any recoverable damages and it is undisputed that she did not seek any form of equitable relief.
Second, as to the retaliation claim, the court applied the McDonnell Douglas burden-shifting framework, which requires a plaintiff to make a prima facie showing of retaliation before the burden shifts back to the employer to offer a legitimate, non-discriminatory reason for its actions. Here, Plaintiff has failed to put forth any evidence of the kind that would demonstrate pretext. She offered nothing more than disagreement with the statements contained in the disciplinary reports. In the absence of any factual record demonstrating that these documented performance deficiencies were inaccurate, Plaintiff has failed to meet her burden of demonstrating pretext. Finally, Plaintiff has failed to show that the final three disciplinary reports were part of the same unlawful employment practice—harassment based on her age and disability.
Court Description: [Shepherd, Author, with Benton and Stras, Circuit Judges] Civil case - Employment discrimination. With respect to plaintiff's FMLA claims, the district court did not err in granting the employer's motion for summary judgment, as plaintiff failed to demonstrate that she sustained any recoverable damages, and it is undisputed that she did not seek any form of equitable relief; nominal damages are not recoverable under the FMLA as they are not included in the specific, statutorily prescribed damages; as to plaintiff's retaliation claim, assuming plaintiff made a prima facie case, she failed to show the legitimate, non-discriminatory basis for her termination - her myriad performance deficiencies - was a pretext for her termination; plaintiff's failure-to-promote claims were untimely; with respect to her age discrimination claim, defendant's stated a legitimate, non-discriminatory ground for termination which plaintiff failed to show was a pretext for discrimination; with respect to plaintiff's hostile work environment claims under the Iowa Civil Rights Act, the claims were time-barred, and were not covered by the continuing violation doctrine.
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.