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By Marshall H. Tanick

The Federal and state appellate courts in Minnesota decided a number of employment law cases in 2020. Here’s a glimpse at a quartet of them at the end of the year.

These four cases reflect the variation in the workplace matters the courts handled last year and extending into 2021 as well.

          Race bias, retaliation claims rejected; employee not re-appointed.  An employee who was terminated from her position with the Federal Emergency Management Agency (FEMA) lost her claim for race discrimination and retaliation after she was not appointed when her term of employment ended.  The Eighth Circuit upheld a ruling of U.S. District Court Judge David Doty, dismissing the case on grounds that the claimant failed to establish a prima facie case of either race discrimination or retaliation.  Moreland v. Wolf, 2020 WL 6498678 (8th Cir. 11/5/2020)  (per curiam).

Retaliation rejected; race, ADA claims denied.  An employee in Minnesota, a claimant of race and discrimination and retaliation lost his claim, too. Dismissal of the pro se claimant’s discrimination action, including claims of race discrimination and violation of the Americans with Disabilities Act (ADA) by Judge Doty was affirmed by the Eighth Circuit, although a partially concurring and dissenting opinion by Judge Jane Kelley would have allowed the retaliation claim to survive a motion to dismiss.  Robinson v. VSI Construction, Inc. 2020 WL 6777998 (8th Cir.11/18/2020) (unpublished).     

Sales representatives act; remanded for “good cause” determination.  An employee in Minnesota who claimed that he was terminated in violation of the Minnesota Termination Of Sales Representatives Act (MTSRA), achieved remand; dismissal of his lawsuit by U.S. District Court Judge Doty in Minnesota.  The Eighth Circuit reversed the lower court’s finding that the act did not apply and remanded for determination whether the employer had “good cause” to terminate the employee.  Engineered Sales Co. v. Endres + Hauser, Inc., 980 F.3d 597 (8th Cir. 11/17/2020).     

Unemployment compensation; mistaken closure of account.  An employee who was ineligible to establish a new unemployment benefits account after he elected to re-activate and receive payments on a pre-existing account.  The Minnesota Court of Appeals held that the unemployment statute made the applicant ineligible for benefits, despite his claim that he made a mistake and in asking for his closure of his account.  Vang v. Medtronic, Inc., 2020 WL 6391289  (Minn. Ct. App. 11/02/2020) (unpublished).