Angela Ames v. Nationwide Mutual Insurance Co, 747 F.3d 509

Ames was hired as a loss-mitigation specialist at Nationwide in Oct 2008, where timely work was a high priority.
She gave birth to her first child in May 2009 and took eight weeks of maternity leave.
She became pregnant again in Oct 2009 and suffered complications requiring bed rest in Apr 2010.
Neel and Brinks allegedly made negative comments about her pregnancies; Ames alleges a hostile environment around maternity leave.
Nationwide reportedly trained a temporary employee to fill Ames’s role during her maternity leave and denied immediate lactation-room access, instead directing her to wait for a wellness room and to complete paperwork; Ames resigned in part due to unresolved lactation and workload pressures.
The district court granted summary judgment for Nationwide on Ames’s Title VII and ICRA discrimination claims, holding no constructive discharge and deeming an actual discharge argument waived on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Constructive discharge viability	Ames claims multiple incidents show intolerable conditions and intent to force resignation.	Nationwide accommodated Ames and did not create intolerable conditions; policies were applied equally.	Constructive discharge claim fails; no reasonable opportunity to remedy was provided and conditions were not intolerable.
Actual discharge argument waiver	Ames argued there was an actual discharge.	Ames did not raise this argument in district court; waived.	Waived; appellate review declined to address actual discharge.

Elam v. Regions Fin. Corp., 601 F.3d 873 (8th Cir. 2010) (direct evidence or McDonnell Douglas-based inference for Title VII discrimination)
Sanders v. Lee Cnty. Sch. Dist. No. 1, 669 F.3d 888 (8th Cir. 2012) (constructive-discharge analysis requires reasonable opportunity to remedy)
Fercello v. County of Ramsey, 612 F.3d 1069 (8th Cir. 2010) (employer accommodation undermines constructive-discharge claim)
Trierweiler v. Wells Fargo Bank, 639 F.3d 456 (8th Cir. 2011) (part of employee’s obligation to be reasonable; not to assume worst)
Coffman v. Tracker Marine, L.P., 141 F.3d 1241 (8th Cir. 1998) (employee must pursue internal channels to remedy issues)
Allen v. Bridgestone/Firestone, Inc., 81 F.3d 793 (8th Cir. 1996) (equal-treatment of employees under policies weighs against inference of discharge)
Schneider v. Jax Shack, Inc., 794 F.2d 383 (8th Cir. 1986) (distinguishes when actual discharge should be addressed on appeal)
McDonald v. City of Saint Paul, 679 F.3d 698 (8th Cir. 2012) (standard for reviewing summary-judgment decisions)