Cynthia Thomas v. Heartland Employment Services
2015 U.S. App. LEXIS 14171
| 8th Cir. | 2015Background
- Thomas, age 53, was employed as an account liaison from May 2010 until June 24, 2011.
- Thomas alleges age-based discrimination by Hagen, an Heartland administrator with indirect supervisory input on termination decisions.
- Hagen allegedly stated in mid-2011 that older people were less productive and commented about keeping younger staff, and called Thomas the 'old short blond girl'.
- Hagen purportedly said he would attend the termination meeting as a witness, while others described a group decision ('we') to terminate Thomas.
- A mileage-audit criticized Thomas's reimbursement claims as falsified, leading Duncan to conclude termination was required; Duncan informed Hagen of the audit results.
- The district court granted summary judgment for defendants; the court of appeals reverses as to Hagen and Heartland, remanding for trial on Thomas’s MHRA claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Hagen a decisionmaker or closely involved in the termination? | Hagen participated; statements show involvement in the decision. | Hagen was not a decisionmaker and had limited involvement. | Reasonable jury could find Hagen closely involved; remand for trial. |
| Do Hagen's age-based comments constitute direct evidence of discrimination? | Comments reflect discriminatory animus tied to termination. | Remarks are stray/isolated and not tied to decisional process. | Age-related comments could be direct evidence supporting discrimination. |
Key Cases Cited
- Fleshner v. Pepose Vision Inst., P.C., 304 S.W.3d 81 (Mo. 2010) (contributes as 'contributing factor' standard under MHRA)
- Daugherty v. City of Maryland Heights, 231 S.W.3d 814 (Mo. 2007) (Missouri causation standard for discrimination claims)
- Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (U.S. 2000) (credibility determinations are jury functions)
- Elam v. Regions Fin. Corp., 601 F.3d 873 (8th Cir. 2010) (direct vs. indirect evidence delineation)
- Denesha v. Farmers Ins. Exch., 161 F.3d 491 (8th Cir. 1998) (age-based bias evidenced by discriminatory animus)
- Fast v. S. Union Co., 149 F.3d 885 (8th Cir. 1998) (direct evidence of discriminatory attitude proffered)
- Torgerson v. City of Rochester, 643 F.3d 1031 (8th Cir. 2011) (direct evidence considerations in discrimination)
- Holland v. Sam’s Club, 487 F.3d 641 (8th Cir. 2007) (summary judgment standards in discrimination cases)