Knutson v. Schwan's Home Service, Inc.
870 F. Supp. 2d 685
D. Minnesota2012Background
- Knutson, employed by Schwan’s since 1998, was promoted to district GM in 2005 and later became Zumbrota depot location GM in 2007 after rehiring.
- His employment required DOT eligibility and medical certification; job descriptions mandated appropriate driver’s license and medical certification.
- In March 2008 Knutson suffered a penetrating eye injury; surgery followed and prognosis ranged from no vision to 20/20 vision.
- During leave for treatment, Schwan’s did not report the injury to HR and Knutson did not obtain a new DOT certificate or waiver.
- Knutson was not offered other positions and Schwan’s terminated his employment on February 9, 2009.
- Knutson filed an EEOC charge and then suit alleging ADA/MHRA discrimination, breach of contract, and wage claims; Schwan’s moved for summary judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is Knutson disabled under ADA/MHRA? | Knutson allegedly has a vision impairment that substantially limits sight. | Impairment does not substantially limit major life activity; not disabled. | Knutson not disabled; summary judgment on disability. |
| Was Knutson qualified to perform essential functions, including DOT driving? | Being DOT-qualified was not essential since depots are intrastate and operations don’t require driving. | DOT qualification was an essential function of the job. | Knutson not qualified; essential function and lack of certificate support dismissal. |
| Did Schwan’s fail to reasonably accommodate Knutson? | Employer should accommodate by removing the driving requirement. | Essential functions cannot be eliminated; accommodation not warranted. | Summary judgment on failure-to-accommodate claim. |
| Is Knutson entitled to vacation pay, severance, and mileage under contract or wage law? | Contracts entitle these payments upon discharge. | No contract entitles these payments; not wages. | No breach; summary judgment for Schwan’s. |
| Is Knutson entitled to 2008 bonus under the Minnesota Wage Act (§ 181.13)? | Bonus claimed as wages due upon discharge. | Bonus eligibility requires remaining employed in good standing or disability definition under plan; Knutson lacks total disability. | Bonus not owing; summary judgment for Schwan’s. |
Key Cases Cited
- Kirkeberg v. Canadian Pac. Ry., 619 F.3d 898 (8th Cir. 2010) (ADA amendments define disability with individualized substantial limitation standard)
- Albertson’s, Inc. v. Kirkingburg, 527 U.S. 555 (Supreme Court 1999) (monocular vision and substantial impairment analysis under ADA)
- Dovenmuehler v. St. Cloud Hosp., 509 F.3d 435 (8th Cir. 2007) (ADA framework and McDonnell Douglas burden-shifting guidance)
- Rehrs v. Iams Co., 486 F.3d 353 (8th Cir. 2007) (ADA disability and essential functions analysis)
- Lee v. Fresenius Med. Care, Inc., 741 N.W.2d 117 (Minn. 2007) (Minnesota wage timing and what constitutes wages under § 181.13)
- Park Nicollet Clinic v. Hamann, 808 N.W.2d 828 (Minn. 2011) (contract formation and elements for breach claims under Minnesota law)