Minnesota Supreme Court clarifies MHRA standards

The Minnesota Supreme Court issued an important decision in an employment law case on February 8, 2023, that clarifies standards established under the Minnesota Human Rights Act (MHRA).

Background

Barbara Henry was a network technician for the St. Paul Public School District from 1997 to 2017. In 2014, the district hired a new deputy chief, who brought in new supervisors for Henry. In 2016, Henry’s performance review rated her below expectations, and she was issued a performance improvement plan (PIP).

This was the first below expectations rating Henry had received in 19 years. In a follow-up post-PIP review, she was again rated below expectations. Her direct supervisor recommended her termination, and she was given the opportunity to meet with the deputy chief and a union representative to argue against termination.

Henry resigned instead and filed suit, claiming age discrimination and constructive discharge under the MHRA and a hostile work environment. The case eventually made its way to the Minnesota Supreme Court.

Minnesota Supreme Court’s ruling

In a 35-page opinion, the Minnesota Supreme Court made three significant rulings.

First, the court ruled an employee could prove age discrimination on a hostile work environment theory. It said the same severe or pervasive standard from a hostile work environment based on sex applies to a hostile work environment based on age.