Karen Chambers v. The Travelers Companies
668 F.3d 559
8th Cir.2012Background
- Chambers was terminated by Travelers in January 2008 and sued in federal court for defamation, breach of unilateral bonus contract, unpaid wages, age discrimination, and ERISA §510 interference; district court granted summary judgment on all claims.
- Defamation claims centered on communications during the October 10 meeting, the October 22 warning, and the January 21 termination; Travelers sought qualified privilege defense.
- Court held the communications were protected by a qualified privilege exercised properly to investigate employee misconduct.
- Breach of contract claim argued that a discretionary bonus for 2007 was contractually owed; court found bonuses discretionary and not contractually guaranteed.
- Unpaid wages claim under Minn. Stat. § 181.13(a) depended on whether a bonus was earned and unpaid; court held the contract governs earned wages, and Chambers was not contractually entitled to the 2007 bonus.
- ERISA §510 claim alleged interference with severance/pension rights; court found no evidence of specific intent to interfere and that a legitimate reduction-in-force justify discharge.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Defamation privilege was abused | Chambers argues malice; privilege lost due to investigation flaws | Travelers acted under proper occasion and purpose and reasonable cause | Qualified privilege applied; no actual malice shown |
| Breach of contract re: 2007 bonus | Bonus was contractually owed for 2007 | Bonus discretionary; no contractual obligation | Discretionary bonus under policy; no contract entitlement |
| Unpaid wages under Minn. Stat. § 181.13(a) | Nonpayment of earned wages due to discharge | Wages governed by contract; no entitlement to 2007 bonus | Contract governs earned wages; no § 181.13(a) violation |
| Age discrimination under MHRA | Discharge motivated by age | Non-discriminatory performance-based discharge | No evidence of pretext; summary judgment proper |
| ERISA §510 interference | Discharge intended to interfere with benefits | No specific intent to interfere; legitimate RIF defense | No prima facie §510 interference; summary judgment proper |
Key Cases Cited
- Bahr v. Boise Cascade Corp., 766 N.W.2d 910 (Minn. 2009) (defamation privilege requires malice to defeat privilege)
- McClure v. Am. Family Mut. Ins. Co., 223 F.3d 845 (8th Cir. 2000) (defamation privilege and falsity questions; scope of privilege)
- Wirig v. Kinney Shoe Corp., 461 N.W.2d 374 (Minn. 1990) (malice required to defeat privilege)
- Elstrom v. Indep. Sch. Dist. No. 270, 533 N.W.2d 51 (Minn. App. 1995) (employer investigations may rely on employee reports)
- McBride v. Sears, Roebuck & Co., 235 N.W.2d 371 (Minn. 1975) (employer investigations and privilege framework)
- Lee v. Fresenius Med. Care, Inc., 741 N.W.2d 117 (Minn. 2007) (statutory wage claim linkage to contract structure)
- Haas v. Kelly Servs., 409 F.3d 1030 (8th Cir. 2005) (evidence of non-pretext supportive of legitimate discharge)
- Torgerson v. City of Rochester, 643 F.3d 1031 (8th Cir. (en banc) 2011) (pretext framework in Title VII/ MHRA analog)
- Regel v. K-Mart Corp., 190 F.3d 876 (8th Cir. 1999) (non-discriminatory RIF defense against §510 claim)
- Lewis v. St. Cloud State Univ., 467 F.3d 1133 (8th Cir. 2006) (MHRA standard mirrors federal ADEA standard)