Clark v. Matthews International Corp.
639 F.3d 391
8th Cir.2011Background
- Clark, age 57 at termination, worked as an artist in Matthews’ St. Louis Graphics Division since 1992.
- In 2000 Matthews reorganized design teams to pursue primary packaging; Clark was placed on the Blue Team, lacking primary-packaging experience.
- Randall Peek was hired to lead primary-packaging efforts and formed three teams (Blue, Red, Purple) with primary-packaging expertise concentrated on the Purple Team.
- Clark sought a transfer to the Purple Team in 2005 but was deemed not sufficiently skilled for primary packaging.
- Matthews conducted a reduction-in-force from August 2006 to January 2007, terminating Clark on January 31, 2007; terminations targeted older employees, and Clark alleges age discrimination in the decisions to not promote and to terminate him.
- The district court granted summary judgment to Matthews on Clark’s federal ADEA claim and on his MHRA claim; on rehearing, the Eighth Circuit vacated the MHRA disposition and remanded for merits consideration, while affirming the ADEA ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Diversity jurisdiction over MHRA claim exists? | Clark contends diversity not established; amount in controversy uncertain. | Matthews bears burden to show amount > $75,000; back pay and other relief likely exceed $75,000. | Yes, diversity exists; panel rehearing granted to address MHRA merits. |
| MHRA claim viability after panel rehearing? | Age contributed to adverse decisions; triable issue present. | Actions driven by skills and market changes; no direct age-based motive shown. | Clark’s MHRA claim survives summary judgment; triable issue of age contributing factor exists. |
| Whether the MHRA requires “but-for” causation like the ADEA? | Missouri MHRA allows age as a contributing factor, not necessarily the sole cause. | MHRA discrimination requires a contributing factor; age need not be the sole cause. | MHRA liability can attach where age contributed to the adverse action, not necessarily as the sole cause. |
| Procedural posture of remand and scope of review? | Court reverses prior MHRA disposition and remands for merits consistent with this opinion. |
Key Cases Cited
- McNeese v. Bd. of Educ., 373 U.S. 668 (1963) (diversity-remand exception not generally available when diversity exists)
- Meredith v. City of Winter Haven, 320 U.S. 228 (1943) (diversity-remand considerations; state-law issues follow federal jurisdiction)
- Smith v. Ashland, Inc., 250 F.3d 1167 (8th Cir.2001) (consent to diversity acknowledged when parties’ citizenship agreed)
- Daugherty v. City of Md. Heights, 231 S.W.3d 814 (Mo.2007) (MHRA “contributing factor” standard)
- Stanley v. Jer-Den Foods, Inc., 263 S.W.3d 800 (Mo.Ct.App.2008) (retirement inquiries and isolated remarks generally not proving discrimination)
- Hartley v. Dillard’s, Inc., 310 F.3d 1054 (8th Cir.2002) (MHRA less demanding than ADEA)