McBee v. Team Indus., Inc., 925 N.W.2d 222

Background

McBee was a full-time operator at Team Industries' die-casting plant and had a documented spinal condition with a 10-pound lifting/pushing/pulling restriction and advice to avoid certain neck movements.
McBee informed supervisors and HR of the restriction; she worked one shift after showing a note, was later removed from duty, and then terminated after HR concluded her continuing employment was a liability.
Essential operator tasks at issue included changing ram tips (involving parts between ~3–150 lbs), cleaning pits with shovels that when loaded could exceed 10 lbs, and pushing/ pulling filled "gaylords" that could require substantial force; job description listed ability to lift 50 lbs.
McBee sued under the Minnesota Human Rights Act (MHRA) for failure to accommodate; Team moved for summary judgment arguing (1) MHRA does not require an interactive process, (2) McBee could not perform essential functions even with accommodation, and (3) continued employment posed a serious threat to her health.
The district court granted summary judgment for Team; the court of appeals affirmed; the Minnesota Supreme Court granted review.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether MHRA requires an employer-employee interactive process to identify accommodations	McBee: MHRA "steps" to accommodate and undue-hardship language require an affirmative interactive process with the employee	Team: MHRA does not contain an explicit interactive-process requirement; federal regulation language is inapplicable	Court: MHRA does not mandate an interactive process; such a process, if at all, pertains only to undue-hardship defense
Whether McBee was a "qualified disabled person" who could perform essential functions with reasonable accommodation	McBee: testimony (shift lead) and practice (help available; prior 20-lb accommodation) show she could perform essential tasks with assistance or modified methods	Team: job description, occupational-therapist report, and typical task weights show essential duties exceed 10-lb restriction; employer judgment controls	Court: Genuine factual disputes exist about essential functions and whether reasonable accommodations (e.g., assistance, different tools, modified techniques) would suffice; summary judgment improper
Whether continuing McBee's employment posed a "serious threat" to her health or safety	McBee: doctor clarified she could work with the weight restriction; risk of paralysis was not the blanket risk she reported	Team: relied on McBee's statements and doctor’s warnings as supporting risk	Court: No competent medical evidence from employer; factual disputes and the doctor’s tempered testimony preclude summary judgment on the serious-threat defense
Whether employer may rely on undue-hardship excuse without showing documented interactive efforts	McBee: undue-hardship factors require documented good-faith efforts including consultation with the disabled person	Team: undue-hardship is an exception and need only be shown when accommodation is otherwise required	Court: Undue-hardship is an exception; MHRA does not impose a broader mandatory consultative duty beyond what statute requires

Key Cases Cited

Kolton v. County of Anoka, 645 N.W.2d 403 (Minn. 2002) (state court may look to federal interpretations but departs when statutes differ)
Moritz v. Frontier Airlines, Inc., 147 F.3d 784 (8th Cir. 1998) (factors for determining "essential functions")
DLH, Inc. v. Russ, 566 N.W.2d 60 (Minn. 1997) (summary-judgment burden rules)
Doe v. Archdiocese of Saint Paul & Minneapolis, 817 N.W.2d 150 (Minn. 2012) (summary-judgment view to be construed in favor of nonmoving party)
Burchett v. Target Corp., 340 F.3d 510 (8th Cir. 2003) (federal court held interactive process required under MHRA, but federal interpretation not binding on state court)
Denson v. Steak 'n Shake, Inc., 910 F.3d 368 (8th Cir. 2018) (physician restrictions may bar employee from performing job functions under ADA)