Hansen v. Robert Half International, Inc.

Summary

The Minnesota Supreme Court reviewed summary judgment in an employment termination dispute involving the Minnesota Parenting Leave Act and the Minnesota Human Rights Act. The court held that an employee need not expressly invoke the Parenting Leave Act when requesting leave, but an extension of leave does not extend reinstatement rights absent a specific agreement. The court also affirmed judgment for the employer on the retaliation claim because it was not adequately pleaded and on the sex-discrimination claim because the termination resulted from a bona fide reduction in force and pregnancy was not shown to be a motivating factor.

Holdings

1. An employee need not specifically reference or invoke the Minnesota Parenting Leave Act when requesting leave. The employee need only inform the employer of a qualifying reason for the leave and otherwise be eligible for statutory protection.
2. An employer's agreement to extend MPLA leave does not, by itself, extend the employee's right to reinstatement. Reinstatement after an extended leave requires a specific agreement to reinstate.
3. Hansen's amended complaint did not plead an MPLA retaliation claim because it alleged only that her termination was pretextual and did not allege retaliation for requesting or obtaining leave.
4. Hansen failed to establish the additional showing required for a discrimination claim arising from a bona fide reduction in force: evidence that her sex was a factor in the decision to eliminate her position.

Questions Presented

1. Whether an employee must expressly invoke the Minnesota Parenting Leave Act when requesting qualifying leave.
2. Whether an employer's agreement to extend Minnesota Parenting Leave Act leave also extends the employee's statutory right to reinstatement.
3. Whether Hansen pleaded a retaliation claim under the Minnesota Parenting Leave Act.
4. Whether Hansen established the additional showing required for sex-discrimination claims arising from a bona fide reduction in force.

Disposition

affirmed