Jeff Knutson v. Schwan's Home Service, Inc.
711 F.3d 911
| 8th Cir. | 2013Background
- Knutson was a Location General Manager for Home Service, required to be DOT qualified for trucks over 10,000 pounds.
- Knutson held an MEC and was DOT qualified through July 2009 before a March 2008 eye injury.
- After Injury, Home Service placed him on 30-day leave to obtain MEC or transfer to a non-DOT job; he did not obtain either and was fired January 2009.
- Knutson’s final paycheck did not include mileage reimbursement or a bonus.
- Home Service continued to require DOT qualification and treated DOT-qualification as an essential function for his management role.
- The district court granted summary judgment to Home Service on all claims; Knutson appeals.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ADA qualification for essential function | Knutson was disabled and could perform essential duties without DOT driving. | Being DOT qualified to drive a delivery truck is an essential function of the Manager role. | Knutson not qualified to perform essential function; ADA claim fails. |
| Mileage reimbursement existence of contract | Oral contract implied from past reimbursement entitles mileage. | No written contract; no supervisor approval shown; no implied contract proven. | No material fact shows entitlement to mileage reimbursement; no contract implied. |
| Bonus entitlement timing | Knutson should receive bonus due to long-term disability exception. | Bonus determined after termination; not earned under contract terms and plan. | Knutson not entitled to bonus; no genuine issue of material fact. |
Key Cases Cited
- Guyton v. Schwan Food Co., Inc., 125 Fed. Appx. 84 (8th Cir. 2005) (DOT qualifications apply to managers; essential function finding)
- Dropinski v. Douglas County, Neb., 298 F.3d 704 (8th Cir. 2002) (essential functions; reasonable accommodation doctrine)
- Bay v. Cassens Transp. Co., 212 F.3d 969 (7th Cir. 2000) (DOT requirements; employer not obligated to revise job functions)
- Alexander v. Northland Inn, 321 F.3d 723 (8th Cir. 2003) (vacuuming as essential function; considerations of essential duties)
- Summerville v. Trans World Airlines, Inc., 219 F.3d 855 (8th Cir. 2000) (essential function determinations; typically duties still essential despite infrequent performance)
- Jenkins v. Mabus, 646 F.3d 1023 (8th Cir. 2011) (timing of wage-related claims; admissions defeat arguments)
- Caldas v. Affordable Granite & Stone, Inc., 820 N.W.2d 826 (Minn. 2012) (wages earned; timing under Minn. statute)
- Lee v. Fresenius Medical Care, Inc., 741 N.W.2d 117 (Minn. 2007) (definition of earned wages in contract terms)