LaMont v. Independent School District 728, 814 N.W.2d 14

LaMont filed MHRA claims against the School District for hostile environment based on sex and sexual harassment.
District court granted summary judgment: no actionable hostile environment, and conduct not severe or pervasive.
Court of Appeals affirmed, holding MHRA-hostile environment claims limited to sexual harassment under the statute.
Miner’s conduct included demeaning comments about women, gender-based workplace restrictions, and separation of sexes.
LaMont reported concerns to Principal, union steward, and HR; district hired private investigator but credibility questioned.
We hold MHRA permits hostile environment based on sex, but the record shows no severe or pervasive conduct here.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Can MHRA hostile work environment be based on sex without sexualharassment	LaMont: sex discrimination includes hostile environment not requiring sexual conduct	School District: hostile environment limited to sexual harassment under MHRA	Yes, MHRA allows sex-based hostile environment claims
Was the alleged conduct severe or pervasive enough	LaMont: conduct directed at her as a woman is severe/pervasive	District: conduct not severe or pervasive to alter employment conditions	No, claims not sufficiently severe or pervasive

Continental Can Co. v. State, 297 N.W.2d 241 (Minn.1980) (sex discrimination includes sexual harassment; can include other sex-based harassment)
Meritor Savings Bank, FSB v. Vinson, 477 U.S. 57 (U.S.1986) (hostile environment under Title VII proven by discrimination forming hostile environment)
Harris v. Forklift Sys., Inc., 510 U.S. 17 (U.S.1993) (discriminatory conduct must be severe or pervasive to create abuse environment)
Goins v. W. Grp., 635 N.W.2d 717 (Minn.2001) (totality of circumstances standard for severity/pervasiveness)
Faragher v. City of Boca Raton, 524 U.S. 775 (U.S.1998) (establishes framework for hostile environment analysis)