Taylor v. LSI Corp. of America
796 N.W.2d 153
Minn.2011Background
- Taylor was employed by LSI from 1988; promoted in 2001; married Gary Taylor, president of LSI, in June 2001.
- Gary Taylor resigned as president in August 2006; Taylor’s job was terminated between his resignation offer and effective date; duties were reassigned and no replacement was hired.
- Taylor alleged she was terminated due to her marital status in violation of MHRA Minn.Stat. § 363A.08, subd. 2.
- Executive-level statements allegedly made by LSI’s CEO cited that Taylor’s resignation or relocation would make her employment uncomfortable or awkward.
- District court granted summary judgment based on a belief that a direct attack on the institution of marriage was required; court of appeals reversed, remanding for factual development.
- The Supreme Court affirms, holding that the amended MHRA definition of “marital status” does not require a direct attack on the institution of marriage and that remand is appropriate for factual determinations under the correct standard.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether MHRA requires a direct attack on marriage to prove marital-status discrimination | Taylor argues statutory amendment eliminates need for direct attack | LSI argues Cybyske control requires direct attack | Not required; statute unambiguous and broader scope affirmed |
| Whether the 1988 amendment redefining marital status changes the prima facie standard | Amendment supports non-direct-attack approach | Court should apply prior Cybyske standard | Amendment supports broader scope; remand to apply correct standard under statute |
| Whether the case should be remanded for fact-finding under the correct standard | Record insufficient to resolve under new standard | District court should evaluate under proper statutory standard | Remand appropriate to address prima facie case under correct standard |
| Whether prior authorities Kepler and Gunnufson remain controlling after statutory change | Statute supersedes, leaving Kraft/Cybyske guidance outdated | Kepler/Gunnufson rely on amended- language but not directly on standard | Historical cases discussed; remand for district court to apply current statute |
Key Cases Cited
- Kraft, Inc. v. State, 284 N.W.2d 386 (Minn. 1979) (definitions of marital status broaden protected classifications)
- Cybyske v. Independent School District No. 196, 347 N.W.2d 256 (Minn. 1984) (requires direct attack on institution of marriage under prior interpretation)
- State by Cooper v. French, 460 N.W.2d 2 (Minn. 1990) (examines broad MHRA language in non-employment context; informs statutory history)
- Kepler v. Kordel, Inc., 542 N.W.2d 645 (Minn.App.1996) (applies Amended MHRA language in appellate context (rev. denied))
- Gunnufson v. Onan Corp., 450 N.W.2d 179 (Minn.App.1990) (applies amended statute language; discusses marital status claim scope)