Recent Minnesota Supreme Court rulings favor employees
Employees and other plaintiffs tended to have difficulty succeeding before the Minnesota Supreme Court in the past. That trend appears to be changing, as reflected by two recent decisions that should have significance well beyond the cases themselves. This is good news for those who pursue employment law and civil rights claims in State court going forward.
In the first case, Peterson v. City of Minneapolis, the Minnesota Supreme Court considered whether raising concerns about discrimination through the employer’s internal human resources procedure tolls the limitations period under the Minnesota Human Rights Act. In other words, the Minnesota Supreme Court had to decide if employees preserve the timeliness of their employment and civil rights claims by using an employer’s internal process for addressing those claims before filing them in court.
In Peterson, the Minnesota Supreme Court ruled that raising a discrimination issue in an employer’s internal human resources procedure tolls the limitations period. This decision will have at least two important consequences. First, it will encourage employers to work in good faith together with employees to address swiftly and satisfactorily workplace problems. Second, to the extent employers do not resolve workplace issues adequately, employees will not be punished for attempting first to address the concern internally before going to court.
In the second case, LaPoint v. Family Orthodontics, P.A., the Minnesota Supreme Court considered whether the plaintiff has to prove that her pregnancy status was the “but for” cause of her discharge. As has been explained previously here, “but for” cause does not mean the sole cause. In any event, the Minnesota Supreme Court ruled that a plaintiff need only show that a protected characteristic, such as race, religion, national origin, or – in this case – pregnancy status, actually motivated the employer to take the action being challenged in court. The clarification in LaPoint regarding the legal standard for proving discrimination claims provides a good roadmap for the effective prosecution of discrimination, harassment, and retaliation claims under the Minnesota Human Rights Act in the future.