Clark v. Matthews Intern. Corp.
628 F.3d 462
8th Cir.2011Background
- Clark, age 43, was hired in 1992 by Matthews' St. Louis Graphics Division as an artist designing corrugated packaging.
- Matthews sought to diversify into primary packaging, creating three teams (Blue, Red, Purple) with primary-packaging experience concentrated on the Purple Team.
- Clark was placed on the Blue Team in 2000 and lacked primary-packaging experience; Purple Team members were younger (27, 28, 37).
- Clark requested transfer to the Purple Team in 2005 but was deemed insufficiently skilled for primary packaging; performance reviews showed productivity issues.
- A reduction-in-force from Aug 2006 to Jan 2007 terminated Clark and other older employees; Clark alleges age was a factor in the decision.
- Clark sued Matthews in district court asserting federal (ADEA) and Missouri MHRA claims; district court granted summary judgment on all claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether diversity jurisdiction exists over MHRA claim | Clark contested the record; diversity existed only if amount > $75k. | Matthews argued, burden on Matthews, that back pay likely exceeds $75k, establishing diversity. | Diversity jurisdiction exists over MHRA claim. |
| Whether MHRA requires 'contributing factor' or 'but-for' causation | Age contributed to adverse actions; MHRA requires age to be a reason. | Company cites performance and market changes as reasons; age not required to be substantial factor. | MHRA requires contributing factor; age need not be primary cause. |
| Whether Clark's MHRA claim survives summary judgment | Evidence shows age contributed to inability to join Purple Team and to termination. | Record lacks triable issue; actions driven by skills and market shift, not age. | Summary judgment on MHRA reversed; triable issue exists. |
Key Cases Cited
- Smith v. Ashland, Inc., 250 F.3d 1167 (8th Cir.2001) (consent cannot confer jurisdiction; record must show diverse citizenship and amount)
- Bell v. Hershey Co., 557 F.3d 953 (8th Cir.2009) (burden on party invoking diversity to prove jurisdiction by preponderance)
- 4:20 Commc'ns, Inc. v. Paradigm Co., 336 F.3d 775 (8th Cir.2003) (reaffirming burden of proving diversity by preponderance)
- Usery v. Anadarko Petroleum Corp., 606 F.3d 1017 (8th Cir.2010) (amount in controversy depends on value of relief sought)
- Hartley v. Dillard's, Inc., 310 F.3d 1054 (8th Cir.2002) (back pay and MHRA considerations in damages analysis)
- Daugherty v. City of Maryland Heights, 231 S.W.3d 814 (Mo.2007) (MHRA requires a contributing factor; age need not be sole cause)
- Fleshner v. Pepose Vision Inst., 304 S.W.3d 81 (Mo.2010) (Missouri Supreme Court on MHRA factors and age discrimination)
- Stidham v. Minn. Mining & Mfg., Inc., 399 F.3d 935 (8th Cir.2005) (statistical significance standard in MHRA discrimination analysis)
- Clark v. Matthews Int'l Corp., 628 F.3d 462 (8th Cir.2010) (panel opinion; addressed ADEA and MHRA posture and remand disposition)