Inge Smothers v. Rowley Mem. Masonic Home, No. 21-3038 (8th Cir. 2023)
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Plaintiff sued her former employers, Rowley Memorial Masonic Home and Rowley Masonic Assisted Living Community, LLC (collectively, Rowley), as well as the Administrator, and Director of Nursing, for age discrimination under the Iowa Civil Rights Act (ICRA) and the Age Discrimination in Employment Act (ADEA). Plaintiff argued that the district court erred by denying her motion to compel and granting summary judgment to Defendants. She also moved to certify a question of law to the Iowa Supreme Court and to supplement the record under seal.
The Eighth Circuit affirmed the district court’s judgment, denied the motion to certify, and granted the motion to supplement. The court held that Plaintiff provided no basis for her speculation that Lemke’s additional answers would yield evidence of age discrimination. In light of the likely minimal relevance of the investigator’s additional answers and the fact that at least some of the information Plaintiff seeks was discoverable from other sources, the court wrote it perceives no abuse of the district court’s discretion and cannot say that its denial of the motion resulted in fundamental unfairness to her. Further, the court held that because Plaintiff cannot create an inference that Defendants’ decisions were motivated by her age, she has failed to make a prima facie case of age discrimination
Court Description: [Wollman, Author, with Kelly and Kobes, Circuit Judges] Civil case - Employment Discrimination. The district court did not abuse its discretion by denying plaintiff's motion to compel the Iowa Department of Inspection and Appeals to provide additional information about an investigation into plaintiff's conduct; plaintiff failed to provide direct evidence of age discrimination; applying the McDonnell Douglas framework to the claim, plaintiff failed to present any evidence that created an inference that age discrimination motivated her five-day suspension or her indefinite suspension; plaintiff failed to show that age discrimination motivated defendant's decision to deny her backpay as she failed to show substantially younger, similarly situated employees received back pay; because plaintiff has failed to create an inference that defendant's decisions were motivated by her age, she failed to make a prima facie case of age discrimination; plaintiff failed to raise an inference of age discrimination, and so she failed to establish her claim of constructive discharge under Iowa law.
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