St. Martin v. City of St. Paul, 680 F.3d 1027

Background

St. Martin, a City firefighter since 1992, was promoted to captain in 1999 and injured his knee in 2006, later returning on light duty.
He sought the fire district chief position in 2007, took a four-part exam, ranked second, but was not promoted after an interview panel; Butler had ultimate decision authority.
In a 2008 interview, Butler questioned St. Martin’s knee and indicated either not promoting or seeking other options; emails suggested Disabling status and reluctance to promote.
In 2009 another fire district chief opening occurred; St. Martin interviewed but was not promoted; May 2009 interview was followed by disability retirement in 2009 and later work as fire inspector.
St. Martin filed a disability discrimination charge with the EEOC before May 2009 interviews; EEOC dismissed but invited suit; district court granted summary judgment for City, finding no ADA MHRA disability and no exhaustion for May 2009 claim.
The district court held St. Martin did not show disability under ADA or MHRA and dismissed the MHRA claim; the court also held the May 2009 interview was not part of his EEOC charge and exhausted remedies were lacking for ADA claim.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is St. Martin disabled under ADA and MHRA?	St. Martin contends knee impairment substantially/ materially limits working.	City argues no substantial/material limitation; no broad class of jobs affected; no perceived disability.	No; not disabled under ADA or MHRA.
Is there direct evidence of discrimination or pretext?	Butler’s statements show discriminatory motive and “regarded as disabled.”	Statements are not direct evidence of a disability; decisions based on qualifications.	No direct evidence; no pretext shown; ADA claim failed.
Did St. Martin exhaust administrative remedies for the May 2009 ADA claim?	MHRA claim can proceed if within one year; May 2009 discrimination within one year.	ADA claim from May 2009 not exhausted; May 2009 interview not within EEOC charge.	ADA claim for May 2009 not exhausted; MHRA claim properly analyzed and dismissed.
Does MHRA definition allow a lesser standard of disability to support a claim?	MHRA uses a “materially limits” standard; could show material limitation.	Even under MHRA's lesser standard, no material limitation shown.	MHRA claim dismissed.

Key Cases Cited

Knutson v. Ag Processing, Inc., 394 F.3d 1047 (8th Cir.2005) (substantial limitation standard for 'working')
Sutton v. United Air Lines, Inc., 527 U.S. 471 (Supreme Court 1999) (definition of substantial impairment under ADA)
Nyrop v. Indep. Sch. Dist. No. 11, 616 F.3d 728 (8th Cir.2010) (direct evidence and discrimination standards)
Kirkeberg v. Canadian Pac. Ry., 619 F.3d 898 (8th Cir.2010) (MHRA/materially limits standard vs. substantially limits)
Sigurdson v. Carl Bolander & Sons, Inc., 532 N.W.2d 225 (Minn. 1995) (Minnesota disability standard in MHRA)
Libel v. Adventure Lands of Am., Inc., 482 F.3d 1028 (8th Cir.2007) (direct evidence not requiring McDonnell Douglas if direct)
Griffith v. City of Des Moines, 387 F.3d 733 (8th Cir.2004) (definition of direct evidence in discrimination cases)
Weber v. Strippit, Inc., 186 F.3d 907 (8th Cir.1999) (regarded-as disability claims; direct evidence standard)
Conant v. City of Hibbing, 271 F.3d 782 (8th Cir.2001) (working as a major life activity; substantial limitation)
Arraleh v. Cnty. of Ramsey, 461 F.3d 967 (8th Cir.2006) (direct evidence and mixed-motive discrimination)
Rivers-Frison v. Southeast Mo. Cmty. Treatment Ctr., 133 F.3d 616 (8th Cir.1998) (discriminatory remarks and decisional process)
King v. United States, 553 F.3d 1156 (8th Cir.2009) (direct evidence in discrimination decisions)
Radabaugh v. Zip Feed Mills, Inc., 997 F.2d 444 (8th Cir.1993) (direct evidence in discrimination claims)
Ostrowski v. Atlantic Mut. Ins. Cos., 968 F.2d 171 (2d Cir.1992) (examples of direct evidence in discrimination)
Torgerson v. City of Rochester, 643 F.3d 1031 (8th Cir.2011) (summary judgment standard)