Matthews v. Eichorn Motors, Inc.
800 N.W.2d 823
Minn. Ct. App.2011Background
- Matthews, a former Eichorn Motors employee, alleged Coombe sexually harassed her; Eichorn Motors was controlled by Justin Eichorn (85%) and Michael Coombe (15%), with Mitch Eichorn (Justin’s father) involved in operations but not an owner or employee.
- Coombe, Eichorn Motors’ general manager, repeatedly made inappropriate sexual advances and remarks toward Matthews beginning May 2006; Matthews reported concerns to Mitch Eichorn and others.
- Matthews was terminated on August 15, 2006, after Coombe and Justin Eichorn confronted her about “not following procedures,” amid ongoing harassment allegations.
- Matthews claimed Mitch and Justin Eichorn aided or abetted Coombe’s harassment and sought to hold Eichorn Motors liable as the employer under MHRA; Mitch and Justin moved for summary judgment.
- The district court granted summary judgment for Mitch and Justin, holding lack of genuine issue of material fact on aiding-and-abetting and rejecting application of the responsible-corporate-officer doctrine to MHRA claims.
- The Minnesota Court of Appeals affirmed, holding that Restatement (Second) of Torts § 876(b) governs aiding-and-abetting under the MHRA and that the responsible-corporate-officer doctrine does not apply to MHRA claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there was a genuine issue of material fact on aiding-and-abetting MHRA claims | Matthews argues defendants aided or abetted Coombe’s harassment | Eichorns contend no substantial evidence of aiding or knowledge | No genuine issue; summary judgment affirmed |
| Whether the responsible-corporate-officer doctrine applies to MHRA claims | Matthews argues individual officers may be liable | Doctrine not applicable to MHRA or private MHRA claims | Doctrine does not apply to MHRA claims; affirmed court rule |
Key Cases Cited
- Wallin v. Minn. Dept. of Corr., 598 N.W.2d 393 (Minn.App.1999) (aiding-and-abetting not shown; discrimination must be proven)
- Frieler v. Carlson Mktg. Grp., Inc., 751 N.W.2d 558 (Minn.2008) (rejects strict-liability framing for MHRA; limits corporate officer liability)
- RSJ v. Beaulieu, 532 N.W.2d 610 (Minn.App.1995) (MHRA not strict liability; corporate-officer liability discussed)
- Witzman v. Lehrman, Lehrman & Flom, 601 N.W.2d 179 (Minn.1999) (Restatement (Second) of Torts standard applied to aiding and abetting)
- Carr v. United Parcel Serv., 955 S.W.2d 832 (Tenn.1997) (recognizes Restatement-based aiding-and-abetting liability)
- Failla v. City of Passaic, 146 F.3d 149 (3d Cir.1998) (adopts Restatement (Second) standard for aiding and abetting in discrimination)