Blakley v. Schlumberger Technology Corp., 648 F.3d 921

Blakley, an African American female, was employed as a dispatcher for Schlumberger in Conway, Arkansas, and was promoted in February 2007 to a financial administrative‑assistant role.
In 2007 Blakley alleged in Suit 1 that her promotion was delayed due to pregnancy, race, and disability; she took leave in Sept–Nov 2007 and planned parental leave starting Jan 2008.
Schlumberger outsourced her duties and eliminated her position, terminating Blakley on January 22, 2008, after which she filed an EEOC charge alleging race discrimination and retaliation.
She filed the instant suit on November 5, 2008, asserting multiple Title VII, PDA, FMLA, and Arkansas-law claims, some of which the district court previously dismissed.
Discovery disputes and sanctions issues arose; Blakley amended her complaint in February 2010; the court later dismissed the Ledbetter Act claim and narrowed discovery, leading to a July 2010 summary judgment ruling in Schlumberger’s favor on remaining claims.
The district court awarded Schlumberger costs; Blakley appeals the interlocutory orders, the discovery rulings, and the summary judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the discovery orders were proper	Blakley contends the court abused its discretion in shutting down discovery and imposing limits.	Schlumberger argues the court appropriately managed discovery and sanctions given conduct and timetables.	No abuse; district court acted within its discretion.
Whether the district court properly dismissed claims	Blakley challenges exhaustion, jurisdiction, and duplicative claims dismissals as overly broad.	Schlumberger asserts valid exhaustion, exclusive-jurisdiction, and duplicative-claims rulings.	Affirmed; dismissals proper.
Whether the Ledbetter Act claim was properly addressed	Blakley argues the Ledbetter claim should proceed or be allowed to be added.	Schlumberger notes lack of leave to amend and procedural constraints; added claim would cause delay.	Ledbetter claim properly dismissed for lack of leave to amend.
Whether summary judgment on remaining claims was correct	Blakley argues genuine issues of material fact exist on hostile environment and FMLA claims.	Schlumberger contends no triable issues and that the record supports summary judgment.	Affirmed; hostile environment, FMLA interference, and FMLA retaliation claims resolved in Schlumberger's favor.

Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (plausibility standard for pleading)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (pledges plausible claims, not mere speculative recitals)
Faibisch v. Univ. of Minn., 304 F.3d 797 (8th Cir. 2002) (EEOC charges treated as public records on motions to dismiss)
Frausto v. Frausto, 636 F.3d 992 (8th Cir. 2011) (waiver of issues for lack of argument on appeal)
Stallings v. Hussmann Corp., 447 F.3d 1041 (8th Cir. 2006) (FMLA interference standard and retaliation framework)
Wierman v. Casey's Gen. Stores, 638 F.3d 984 (8th Cir. 2011) (McDonnell Douglas framework for retaliation claims)
Green v. Franklin Nat'l Bank of Minneapolis, 459 F.3d 903 (8th Cir. 2006) (elements of hostile-work-environment claim)
Parkhill v. Minn. Mut. Life Ins. Co., 286 F.3d 1051 (8th Cir. 2002) (avoidance of duplicative litigation; permissibility of dismissal on 12(b)(1)-(6) grounds)
Lorenz v. Valley Forge Ins. Co., 23 F.3d 1259 (7th Cir. 1994) (costs may be awarded separately from merits on appeal)
Cleaver v. Kemna, 122 Fed.Appx. 863 (8th Cir. 2004) (liberal notice-appeal rules; lack of appeal on costs)