Taylor v. LSI Corp. of AmericaTaylor v. LSI Corp. of America
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 madе a prima facie 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 uncоmfortable or awkward remaining employed 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 reаsons.
In January 2009, LSI moved for summary judgment seeking dismissal 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 Taylоr’s termination was an act “directed at the institution of marriage,” as required by our decision in Cybyske v. Independent School District No. 196,
The court of appeals found thе language of the statute to be unambiguous and concluded 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 parties in this case is whether “marital status” discrimination as defined in
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
While we do not rely on it for our conclusion that
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, оr a surviving spouse and, in employment cases, 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
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 mаrital status discrimination, we should nonetheless reverse the 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, thеse facts are drawn from the limited record before us. They are only 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