Jeff Bonomo v. The Boeing Company, 63 F.4th 736

Jeff Bonomo, a long‑time Boeing employee (hired 1985), applied for internal promotions in 2017 and 2018 and scored lowest among interviewees both times; younger candidates (age 33 in 2017 and age 34 in 2018) were selected.
Boeing uses a standardized, structured interview process with panel scoring; hiring managers may check a box indicating selection was based solely on the structured interview.
The 2018 selectee, Daniel Oetjen, had served as interim manager and holds a master’s degree (a preferred qualification); panelists rated Oetjen’s interview substantially higher than Bonomo’s.
Bonomo retired after giving notice by email on November 25, 2019, completed termination paperwork December 2, 2019, and filed a constructive‑discharge charge with the Missouri Commission on Human Rights on May 28, 2020.
The district court granted summary judgment for Boeing on both the MHRA age‑discrimination (failure to hire) claim and the constructive‑discharge claim (dismissed as untimely); the Eighth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Boeing’s stated reason for hiring Oetjen (structured interview scores) was pretext for age discrimination under the MHRA/McDonnell Douglas framework	Bonomo: panel composition, reliance solely on interview (contrary to handbook), omission of initial written reason, pattern (2017 & 2018), and that Oetjen was less qualified together permit an inference of age animus	Boeing: legitimate, nondiscriminatory reasons—poor interview performance by Bonomo, consistent interviewer testimony, Oetjen’s superior interview and preferred master’s degree, policy permits interview‑only selection	Affirmed summary judgment for Boeing; plaintiff failed to show genuine dispute of material fact that interview reason was pretext for intentional age discrimination
Whether Bonomo’s constructive‑discharge claim was timely under the MHRA (180‑day filing rule)	Bonomo: limitations period began when he completed termination paperwork (Dec 2, 2019)	Boeing: accrual triggered when Bonomo gave notice of resignation (Nov 25, 2019) per Green v. Brennan	Affirmed dismissal as untimely: accrual on notice (Nov 25, 2019); charge filed May 28, 2020 was 185 days later and thus barred

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden‑shifting framework for discrimination cases)
St. Mary’s Honor Ctr. v. Hicks, 509 U.S. 502 (plaintiff must persuade factfinder of intentional discrimination)
Green v. Brennan, 578 U.S. 547 (constructive‑discharge claim accrues on date employee gives notice of resignation)
Lampley v. Mo. Comm’n on Hum. Rts., 570 S.W.3d 16 (Missouri en banc guidance applying MHRA consistent with federal law)
Lombardo v. City of St. Louis, 38 F.4th 684 (summary‑judgment standard; view facts for nonmoving party)
Canning v. Creighton Univ., 995 F.3d 603 (plaintiff must offer sufficient evidence for trier of fact to infer discrimination)
Lake v. Yellow Transp., Inc., 596 F.3d 871 (failure to follow employer policies can support inference of pretext)