Hoover v. Norwest Private Mortgage Banking

Summary

The Minnesota Supreme Court reviewed summary judgment in Dianne Hoover's claims under the Minnesota Human Rights Act for disability discrimination, failure to make reasonable accommodations, and reprisal. The court held that genuine issues of material fact existed regarding whether Hoover was disabled, whether Norwest knew of her need for accommodation, and whether the stated reason for her termination was pretextual. It affirmed reinstatement of the discriminatory-discharge claim, reversed dismissal of the reasonable-accommodation and reprisal claims, and remanded for further proceedings.

Holdings

1. Hoover presented sufficient evidence to create genuine issues of material fact as to whether she was disabled, qualified for her position, replaced by a nondisabled person, and discharged for a reason that was pretextual and discriminatory. Summary judgment on the discriminatory discharge claim was therefore improper.
2. The evidence created a genuine issue of material fact as to whether Hoover's fibromyalgia materially limited the major life activity of working and therefore constituted a disability under the MHRA.
3. Summary judgment for Norwest on Hoover's reasonable-accommodation claim was improper because the record created genuine issues of material fact as to whether Norwest knew of her disability-related need for loan-processing support.
4. A request for work assistance is protected activity under the MHRA when the employee specifically ties the request to a disability. Hoover presented sufficient evidence of protected activity, adverse action, causation, and pretext to survive summary judgment on her reprisal claim.

Questions Presented

1. Whether genuine issues of material fact existed as to whether Hoover was disabled under the Minnesota Human Rights Act and was discharged because of her disability.
2. Whether genuine issues of material fact existed as to whether Norwest knew of Hoover's disability-related need for loan-processing support and failed to provide a reasonable accommodation.
3. Whether Hoover engaged in statutorily protected activity by requesting work assistance tied to her fibromyalgia and whether a factual issue existed as to whether her termination was reprisal for that activity.
4. What showing of pretext is required to avoid summary judgment under the McDonnell Douglas framework.

Disposition

reversed_and_remanded