The Minnesota Supreme Court today issued an important decision clarifying and broadening the contours of marital discrimination in light of recent legislative changes.
LeAnn Taylor began working for LSI in 1988 as a receptionist/secretary. In February 2001, she was promoted to Sales and Marketing Coordinator. In June 2001, she married Gary Taylor, the president of the company. Five years later, however, Gary Taylor resigned from LSI. Shortly after his resignation, LSI fired LeAnn as well. LSI did not hire anyone to replace Taylor and her duties were reassigned to other employees.
In her complaint, Taylor alleged that she was terminated due to her ‘marital status,’ in violation of Minn. Stat. § 363A.08, subd. 2 (2010). Section 363A.08, subdivision 2, provides that “it is an unfair employment practice for an employer, because of . . . sex [or] marital status . . . [to] discharge an employee.” According to Taylor, the chief executive officer of LSI’s parent company told Gary Taylor that he would like to terminate LeAnn because she would be uncomfortable or awkward remaining employed with the company after Gary left. LeAnn also claims that the CEO told her directly that “due to her husband’s situation”, and the fact that it was likely that the Taylors were going to have to relocate, LSI was eliminating her position. LSI denies those statements , and instead claims that Taylor was fired for legitimate business-related reasons.
The district court dismissed Taylor’s complaint on the basis of a 1984 decision by the Supreme Court indicating that the act in question must be “directed at the institution of marriage”. On appeal, Taylor argued that that requirement had been overruled by the legislature’s subsequent amendment defining marital status as including “protection against discrimination on the basis of the identity, situation, actions, or beliefs of a spouse or former spouse.” Minn. Stat. § 363A.03, subd. 24 ( 2010).
The issue before the Supreme Court, therefore, was narrow: whether “marital status” discrimination requires a plaintiff to prove that the employer’s action constitutes a “direct attack” on the institution of marriage. Examining the amended language of the MHRA, the Court unanimously found that the statute is clear: an employer cannot discharge an employee because of marital status, which includes discrimination on the basis of “the identity, situation, actions, or beliefs of a spouse or former spouse.” Thus, the statute extends protection against marital status discrimination to include the identity of the employee’s spouse and the spouse’s situation, as well as the spouse’s actions and beliefs. Therefore, a plaintiff is not required to show that termination was directed at the institution of marriage in order to establish a marital status discrimination claim.