Quinn v. St. Louis County
653 F.3d 745
| 8th Cir. | 2011Background
- Quinn, a St. Louis County employee, reported sexual harassment by a County Commissioner in Feb 2007 and settled, releasing the County from liability in exchange for seven years of employment protections.
- Post-settlement, Quinn experienced stress and availed FMLA leave from May 14 to Aug 10, 2007; upon return, she faced alleged retaliation and workplace changes.
- In early 2008 Mitchell became County Administrator, Quinn’s supervisor, and allegedly subjected her to belittling conduct and scheduling/tardiness disputes.
- Quinn sought and received an adjusted work schedule in 2008 and then full or extended leave; doctors later indicated Quinn could not return to work for the County.
- In May 2009 Quinn sued for MHRA reprisal discrimination, FMLA interference/retaliation, breach of contract, and other claims; the district court dismissed the breach claim with prejudice and granted summary judgment on MHRA and FMLA claims.
- This appeal challenged the dismissal of the breach-of-contract claim, denials of amendments/reconsideration, and the summary judgments on MHRA and FMLA claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the breach of contract claim was properly dismissed | Quinn contends the claim survives under Rule 12(b)(6) or should be amended. | County argues no discharge or constructive discharge; claim fails as a matter of law. | Summary: harmless dismissal; constructiveness not proven; affirmed. |
| Whether MHRA retaliation summary judgment was proper | Quinn asserts disputed facts show retaliatory actions would dissuade a reasonable employee. | County asserts no genuine issue of material fact on adverse action and causal link. | Summary judgment affirmed; no material adverse action shown. |
| Whether MHRA constructively discharged evidence supports retaliation claim | Quinn argues hostile conditions and intent to force quit prove constructiveness. | County argues its actions included accommodation and encouragement to return to work. | Constructive discharge rejected; no evidence of intent to force resignation. |
| Whether FMLA interference summary judgment was proper | Quinn claims County discouraged or manipulated leave approvals. | Quinn received full 12 weeks of FMLA leave annually requested. | Summary judgment affirmed; no denial of entitlements. |
| Whether FMLA retaliation summary judgment was proper | Quinn asserts adverse action due to exercising FMLA rights. | No adverse action established; constructive discharge lacking. | Summary judgment affirmed; no genuine adverse action. |
Key Cases Cited
- Fercello v. County of Ramsey, 612 F.3d 1069 (8th Cir. 2010) (constructive discharge and retaliation standards; objective analysis required)
- Devin v. Schwan's Home Service, Inc., 491 F.3d 778 (8th Cir. 2007) (materially adverse action may be shown by cumulative or individual acts)
- Anda v. Wickes Furniture Co., 517 F.3d 526 (8th Cir. 2008) (employer intent shown by actions indicating retention of employee)
- Carpenter v. Con-Way Central Express, Inc., 481 F.3d 611 (8th Cir. 2007) (constructive discharge framework for retaliation cases)
- Doe ex rel Tsai, 648 F.3d 584 (8th Cir. 2011) (requirement that factual disputes be tied to legal elements)
- Scobey v. Nucor Steel-Ark., 580 F.3d 781 (8th Cir. 2009) (adverse-action standard and retaliation analysis in FMLA context)