Minnesota Supreme Court Holds that Marital Status Discrimination Need Not be Directed at the “Institution of Marriage” to be Illegal
May 09, 2011
by Julia H. Halbach
On April 13, 2011, the Minnesota Supreme Court issued its decision in Taylor v. LSI Corp. of America, ___ N.W.2d ___, 2011 WL 1376737(Minn. 2011). The Court’s decision clarified the marital discrimination language of the Minnesota Human Rights Act (“MHRA”) to make clear that marital status discrimination is unlawful, even if it is not directed at the “institution of marriage.”
Factual Background and Procedural History: The plaintiff, LeAnn Taylor, began working for LSI Corporation of America (“LSI”) in 1998 as a receptionist. In 2001, she was promoted to the Sales and Marketing Coordinator, and she married Gary Taylor, LSI’s President, that same year. Gary Taylor was forced to resign his role as President in August 2006. Shortly after Mr. Taylor’s resignation became public, LSI terminated Ms. Taylor’s employment. The company did not hire anyone to replace Ms. Taylor, and her job duties were reassigned to other employees.
After her termination, Ms. Taylor sued LSI, claiming that the company had terminated her based on her “marital status” in violation of the MHRA. Ms. Taylor alleged that the CEO of LSI’s parent company told her husband that LSI terminated Ms. Taylor because she would likely be “uncomfortable or awkward” having to continue working for the company from which her husband had been forced to resign. LSI denied Ms. Taylor’s allegations and stated that Ms. Taylor had been terminated for legitimate, non-discriminatory business reasons.
LSI moved for dismissal, based on the fact that Ms. Taylor had failed to allege that LSI’s discrimination was directed at the “institution of marriage,” rather than at her status as a married person. Based on a previous opinion from the Minnesota Supreme Court, the trial court agreed with LSI and dismissed Ms. Taylor’s claims.
Ms. Taylor appealed the trial court’s dismissal. The Minnesota Court of Appeals agreed with Ms. Taylor and reversed the trial court’s decision. The Court of Appeals stated that any type of discrimination based on a person’s marital status, including the actions or identity of an employee’s spouse, can constitute unlawful discrimination. The Court of Appeals further stated that marital discrimination does not need to be an attack on the “institution of marriage” to be unlawful. LSI appealed the Court of Appeals’ decision, and the Minnesota Supreme Court agreed to hear the case.
Minnesota Supreme Court Opinion: The Minnesota Supreme Court affirmed the Court of Appeals’ decision. The Court first analyzed the language of the MHRA and concluded that it unambiguously states that an employer cannot discharge an employee “because of … marital status.” The Court went on to state that “marital status” is defined broadly by the statute, and is not limited to discrimination against the “institution of marriage.” Specifically, the Court recognized the fact that the definition of “marital status” can include discrimination based on the identity and actions of a person’s spouse. Accordingly, the Court concluded that in this case, Ms. Taylor had alleged actions (discrimination based on her spouse’s status as the former President of LSI) to survive dismissal. The Court chose not to decide whether Ms. Taylor’s claims had merit, and instead sent the case back to the trial court for further proceedings on that question.
What this Case Means for Employers: This is the first time that the Minnesota Supreme Court has interpreted what “marital status” discrimination means since the legislature amended the statutory language in 1988. While the Court had previously considered the question, the amendments to the statutory language in 1988 created some confusion for courts, attorneys, and employers. This opinion provides some guidance for employers and attorneys regarding what types of actions by employers are now prohibited by the statute.
While marital status claims are infrequent, employers should nonetheless be aware that a person’s marital status is a protected class, and should take care not to discriminate against an applicant or employee on that basis. Marital status discrimination can arise in many different contexts, such as that seen in this case (where an employee was allegedly terminated because of who her spouse was); or in a case where an employer refuses to hire someone because her spouse is already employed by the company. It is also important to remember that marital status discrimination can apply to any “marital status” – whether that status is single, married, divorced, separated, etc. An employer generally may not discriminate against someone simply because it disagrees with that person’s marital status.
For more information on the subject of this article, contact the author of this article, or the Larkin Hoffman attorney who customarily handles your matters. Larkin Hoffman Daly & Lindgren Ltd. has proudly served the legal and business counseling needs of clients since 1958. The firm includes over 70 attorneys serving clients’ legal needs throughout the state, the country and around the globe. As a full-service law firm, it provides counsel and legal guidance in more than 20 areas of law to clients ranging from individuals to emerging companies and Fortune 500 corporations.
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