OPINION
Rеspondent LeAnn Taylor’s employment with appellant LSI Corporation of America (LSI) was terminated after her husband was forced to resign his employment as president of LSI. Taylor filed a lawsuit against LSI claiming marital status discrimination in violation of the Minnesota Human Rights Act, Minn.Stat. ch. 363A (2010) (MHRA). The district court granted summary judgment to LSI, dismissing Taylor’s claims on the grounds that existing case law requires a plaintiff claiming “marital status” discrimination to allege that the termination was a “direct attack on the institution of marriage,” which Taylor admits she did not assert. The court of appeals reversed, concluding that the plain language of the MHRA does not require a “direct attack on the institution of marriage” and that remand was necessary because a genuine issue of material fact existed as to whether Taylor had made a prima fаcie showing of “marital status” discrimination. Taylor v. LSI Corp. of Am.,
Taylor began her employment with LSI in 1988 as a receptionist/secretary.
In her complaint, Taylor alleged that she was terminated due to her “marital status,” in violation of MinmStat. § 363A.08, subd. 2 (2010). Section 363A.08, subdivision 2, provides that “it is an unfair employment practice for an employer, because of ... sex [or] marital status ... [to] discharge an employee.” According to Taylor, the chief executive officer of LSI’s parent company told Gary Taylor that he would like to terminate Taylor because “she would be uncomfortable or awkward remaining еmployed with [LSI] after Mr. Taylor left Defendant’s employ.” She also claims that the CEO told her directly that “due to her husband’s situation ... and the fact that it was likely [the Taylors] were going to have to relocate, [LSI] was eliminating [her] position.” LSI denies that such statements were made regarding Taylor’s termination, and instead claims that Taylor was fired for legitimate business-related reasons.
In January 2009, LSI moved for summary judgment seeking dismissаl of Taylor’s lawsuit, arguing that the complaint failed to establish a prima facie case of marital status discrimination because it did not allege that Taylor’s termination was an act “directed at thе institution of marriage,” as required by our decision in Cybyske v. Independent School District No. 196,
The court of appeals found the language of the statute to be unambiguous and concludеd that the “legislature defined ‘marital status’ to expressly include the ‘identity, situation, [and] actions’ of an employee’s spouse.” Taylor,
The issue presented by the рarties in this case is whether “marital status” discrimination as defined in Minn.Stat. § 363A.03, subd. 24, requires a plaintiff to prove that the employer’s action constitutes a direct attack on the institution of marriage. When reviewing a grant of summary judgment, we consider two questions, “whether there are any genuine issues of material fact and whether the lower courts erred in their application of the law.” Cummings v. Koehnen,
We conclude that the language of the MHRA, on its face, is unambiguous because it does not lend itself to multiple interpretations or logical inconsistencies in its application. The language of the statute is clear: under Minn.Stat. § 363A.08, subd. 2, an employer cannot discharge an employee “because of ... marital status.” Under Minn.Stat. § 363A.03, subd. 24, “marital status” includes “protection against discrimination on the basis of the identity, situation, actions, or beliefs of a spouse or former spouse.” Reading each term with its “plain and ordinary meaning,” this statute’s language extends protection against marital status discrimination to include the identity of the employee’s spouse and the spouse’s situation, as well as the spouse’s actions and beliefs. Therefore, we conclude, as did thе court of appeals, that Minn.Stat. § 363A.08, subd. 2, in conjunction with Minn.Stat. § 363A.03, subd. 24, does not require a plaintiff to show that termination was “directed at the institution of marriage” in order to establish a “marital status” discrimination claim.
While we do not rely on it for our conclusion that section 363A.03, subdivision 24, does not require a plaintiff to show that the employer’s actions were “directed at the institution of marriage” to establish a marital status discrimination claim, we note that the statute’s history supports that conclusion. The MHRA was originally enacted as the Minnesota State Act for Fair Employment Practices to “foster the employment of all individuаls ... regardless of their race, color, creed, religion, or national origin.” Act of April 19, 1955, ch. 516, §§ 1-2, 1955 Minn. Laws 802, 802-03. The Legislature subsequently amended the act to make it an “unfair employment practice” for an еmployer to refuse to hire, discharge, or discriminate against a person with respect to employment because of a person’s “marital status.” Act of May 24, 1973, ch. 729, § 3, 1973 Minn. Laws 2158, 2161 (codified as amended at Minn.Stat. § 363A.08, subd. 2 (2010)); see also State by Cooper v. French,
We addressed the meaning of the term “marital status discrimination” under the statute in Kraft, Inc. v. State,
Notwithstanding what we said in Kraft, we held in Cybyske that the plaintiff did not have a cause of action for marital status discrimination under the MHRA
Four years after our decision in Cy-byske, the Legislature amended the MHRA to define the term “marital status.” That definition is as follows:
“Marital status” means whether a person is single, married, remarried, divorced, separated, or a surviving spouse and, in employment casеs, includes protection against discrimination on the basis of the identity, situation, actions, or beliefs of a spouse or former spouse.
Act of April 26, 1988, ch. 660, § 1, 1988 Minn. Laws 917, 918 (originally codified at MinmStat. § 363.01, subd. 40 (1988); presently codified at Minn.Stat. § 363A.03, subd. 24 (2010)). Since the 1988 amendment, we have not had occasion to interpret the statute in the employment context.
LSI argues that even if we conclude that a direct attack on the institution of marriage is no longer required to establish a claim of marital status discrimination, we should nonetheless reverse thе court of appeals because Taylor has not otherwise made out a prima facie case of marital status discrimination. We decline to address this argument. The district court dismissed Taylor’s lawsuit based on an erroneous reading of the statutory requirement for a prima facie marital status discrimination claim. As a result, the district court did not consider Taylor’s claims or LSI’s argument that Taylor has failed to make out a prima facie case using the correct statutory standard. In our view, the issues raised by LSI’s argument are best addressed by the district court in the first instance. See Thiele v. Stick,
Affirmed.
Notes
. Because this case was dismissed prior to the district court making factual determinations, these facts are drawn from the limited record before us. They are оnly to provide context for the claim and to frame the legal issue, but are not factual findings by this court.
. For purposes of clarity, “Taylor” refers to LeAnn Taylor and “Gary Taylor” refers to her husband.
. The court of appeals has applied the amended language of section 363A.03, subdivision 24, in two published opinions: Kepler,
