Norah Oehmke v. Medtronic, Inc.
844 F.3d 748
| 8th Cir. | 2016Background
- Oehmke, a cancer survivor with long-term health effects (suppressed immune system, cardiomyopathy), worked for Medtronic from 2003 and later as a Senior Patient Services Specialist.
- She frequently requested telework and schedule accommodations to attend medical appointments; supervisors sometimes granted informal accommodations but later restricted telework and changed schedules after supervisor turnover.
- Between 2008–2010 Medtronic documented customer complaints about Oehmke, questioned her call notes, criticized her communication style, and eventually reassigned her to a more burdensome CareLink Specialist role after extended medical leaves.
- Medtronic placed Oehmke on a PIP, suspended her after a contentious meeting, offered a separation agreement which she rejected, and then terminated her employment on March 26, 2010.
- Oehmke sued under the ADA and Minnesota Human Rights Act alleging disability discrimination (disparate treatment) and retaliation; the district court granted summary judgment to Medtronic and the Eighth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Oehmke is disabled under the ADA | Her cancer and lingering effects (suppressed immune system, cardiomyopathy) substantially limit major life activities | Even if cancer in remission, Medtronic contends plaintiff did not show disability caused absences or need for accommodations | Court treated cancer/remission and lingering effects as covered but resolution of causation did not depend on labeling; disability recognized as potentially covered |
| Causation for disparate-treatment claim | Termination motivated at least in part by disability-related absences and refusal to accommodate schedule/telework | Legitimate nondiscriminatory reasons: performance problems, patient-safety error, insubordination, policy violations; termination followed suspension and rejection of settlement | Mixed-motive standard applied; record lacked sufficient causal link between disability/accommodation needs and termination — summary judgment for Medtronic affirmed |
| Pretext for employer’s nondiscriminatory reasons | Employer manufactured complaints, miscalculated absenteeism, created a miserable position to force her out | Performance issues and legitimate business needs (call volumes, procedural violations) explain actions | Court did not reach pretext in depth because plaintiff failed to establish prima facie causation; judgment for Medtronic upheld |
| Retaliation (ADA & MHRA) — causation and protected activity | Meeting with in-house counsel and rejection of settlement were protected; termination was retaliatory | No evidence that meeting or rejection motivated termination; rejection of settlement not protected activity; employer decisions driven by performance and procedural issues | Retaliation claim failed for lack of but-for causation (ADA) and no evidence of retaliatory motive (MHRA) — summary judgment for Medtronic affirmed |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for discrimination claims)
- Gross v. FBL Financial Servs., Inc., 557 U.S. 167 (but-for causation discussion referenced regarding ADEA and potential relevance to ADA)
- Univ. of Tex. Sw. Med. Ctr. v. Nassar, 133 S. Ct. 2517 (but-for causation required for retaliation under ADA)
- Pedigo v. P.A.M. Transport, Inc., 60 F.3d 1300 (mixed-motive causation standard cited)
- Pulczinski v. Trinity Structural Towers, Inc., 691 F.3d 996 (discussion of pre-Gross ADA precedent and causation issues)
- Kammueller v. Loomis, Fargo & Co., 383 F.3d 779 (MHRA disability standard comparison)