ALERT - Minnesota Supreme Court Determines Standard for Marital Status Discrimination ClaimsPrint PDFShare
On April 13, 2011, the Minnesota Supreme Court overturned long-standing precedent and clarified the standard for establishing a prima facie case of marital status discrimination under the Minnesota Human Rights Act. The Court held that a plaintiff does not need to establish his or her employer’s alleged discriminatory conduct was “directed at the institution of marriage.” Taylor v. LSI Corp. of Am., No. A09-1410 (Minn. 2011) overruling Cybyske v. Ind. Sch. Dist. No. 196, 347 N.W.2d 256, 261 (Minn. 1984). In Taylor, the Court reasoned that the 1988 amendments to the Human Rights Act defined “martial status” in a manner that expanded the prohibition on marital-status discrimination beyond the holding in Cybyske.
The plaintiff in the case, LeAnn Taylor, was employed by LSI Corporation as a Sales and Marketing Coordinator. She also was married to LSI’s president, Gary Taylor. When her husband resigned, LSI’s parent corporation terminated Taylor. Taylor alleged that the reason given was that “she would be uncomfortable or awkward remaining with [LSI] after Mr. Taylor left [LSI’s] employ.” Taylor also alleged the CEO of the parent corporation informed her 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 denied these allegations and sought and received summary judgment. In the District Court, LSI argued Taylor failed to allege her termination was an act “directed at the institution of marriage” as required in Cybyske. Taylor unsuccessfully argued to the District Court that the legislature had overruled Cybyske when it amended the Human Rights Act.
The Minnesota Court of Appeals agreed with Taylor and reversed summary judgment. The Supreme Court accepted the employer’s petition for review and upheld the Appeals Court ruling. In a unanimous decision, the Court held that the Human Rights Act did not require an attack on marriage itself before marital status discrimination became actionable. The Court stated that the language of the Human Rights Act, as amended, which barred discrimination “on the basis of the identity, situation, actions, or beliefs of a spouse or former spouse[,]” simply did not include such a requirement. The Court found that the language of the Human Rights Act was “unambiguous because it does not lend itself to multiple interpretations or logical inconsistencies in its application.” The Court went on to discuss the legislative history of the Human Rights Act and prior precedent, explaining that the Human Rights Act did not contain a definition of “marital status” prior to 1988, which led to the Cybyske decision. The Court then stated that the 1988 amendments clearly defined marital status in a manner that went beyond Cybyske, but that the Supreme Court had not had an opportunity to interpret the amendment until the current case.
The Taylor decision confirms the broad basis of actionable marital status discrimination claims under the Minnesota Human Rights Act. Accordingly, employers should be cautious whenever a termination decision includes, or is even perceived to include, consideration of the identity or actions of the employee’s spouse. Finally, the Taylor decision should serve as a reminder that supervisors should review any such decisions with a human resources manager or legal counsel prior to implementation.
For more information, contact your Briggs and Morgan attorney or a member of the Employment, Benefits and Labor Section, ranked as a Minnesota Band 1 practice in Chambers USA.