Mandy Liles v. C.S. McCrossan, Inc., 851 F.3d 810

Background

Mandy Liles was hired by C.S. McCrossan (CSM) in 2004 and advanced to assistant project manager; performance concerns arose 2010–2011 after she worked on CCLRT project.
She reported coworker Deb Petry’s lack of crane training (2010) and later reported inappropriate comments by project manager Justin Gabrielson (reported March 2011).
After supervisors documented performance problems, Liles was reassigned to field work in April–May 2011, placed on a Corrective Action Plan (CAP) in November 2011, and terminated January 24, 2012.
Liles alleged Title VII and Minnesota Human Rights Act claims for sex discrimination, sexual harassment (hostile work environment), and retaliation/reprisal; EEOC issued right-to-sue and suit followed.
The district court granted summary judgment for CSM; on appeal the Eighth Circuit reviewed de novo and affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Retaliation / Reprisal (Title VII / MHRA)	Liles engaged in protected complaints (Petry training; Gabrielson conduct) and adverse actions (CAP, termination) were retaliatory.	Temporal gap and lack of evidence of causal link; employer cited legitimate nondiscriminatory reason (poor performance).	Affirmed: temporal distance (8–17 months) and no evidence of causal nexus or but‑for causation defeat claim.
Gender discrimination (termination)	Termination was pretextual; favorable prior history and CAP shortly after "satisfactory" review suggest discrimination.	Termination was based on documented, genuine belief of inadequate performance; employer legitimately relied on performance evaluations and CAP.	Affirmed: plaintiff failed to show pretext—no evidence CSM did not believe performance problems.
Hostile work environment / Sexual harassment	Repeated lewd comments and conduct by coworkers created abusive environment altering terms/conditions of employment.	Incidents were rude/occasional, not sufficiently severe or pervasive to meet objective/subjective hostile‑work‑environment standard.	Affirmed: conduct was not extreme or pervasive enough to alter employment conditions.
Cat’s‑paw / imputed bias theory	Bias of non‑decisionmakers (Senior, Walk) influenced McCrossan’s termination decision; their animus should be imputed.	No evidence Senior/Walk had authority or influence to cause decision; no proof of discriminatory motive by decisionmaker.	Affirmed: plaintiff failed to show subordinate animus was the proximate cause of the adverse action.

Key Cases Cited

University of Texas Southwestern Medical Center v. Nassar, 133 S. Ct. 2517 (U.S. 2013) (Title VII retaliation requires but‑for causation)
Staub v. Proctor Hosp., 562 U.S. 411 (U.S. 2011) (cat’s paw liability where biased subordinate proximately causes adverse action)
Guimaraes v. SuperValu, Inc., 674 F.3d 962 (8th Cir. 2012) (McDonnell Douglas framework and disparate‑treatment analysis)
Dietrich v. Canadian Pac. Ltd., 536 N.W.2d 319 (Minn. 1995) (MHRA causation can rest on inference from timing and knowledge)
Kipp v. Mo. Highway & Transp. Comm’n, 280 F.3d 893 (8th Cir. 2002) (temporal gaps can negate inference of retaliation)