Garrison v. Minnesota Department of Revenue of the State of Minnesota

Background

Peter Garrison, an employee of the Minnesota Department of Revenue, sued the department and three employees: Linda Craigie, Kathy Zieminski, and Pam Evans. His remaining claims were an equal-protection claim under 42 U.S.C. § 1983 against Craigie in her individual capacity; race-discrimination and hostile-work-environment claims under Title VII against the department and Craigie in her official capacity; and a retaliation claim under Title VII against Craigie and Evans in their official capacities.

Garrison alleged that, from about 2012 through early 2015, Craigie supervised him and treated him negatively because of racial bias. He alleged that he was suspended multiple times without cause and later demoted with a corresponding salary reduction. After he filed a race-discrimination charge with the Equal Employment Opportunity Commission, his union filed grievances for him. Garrison and union representatives negotiated with the department, and the parties signed a settlement agreement in March 2015.

Under the agreement, Garrison was reassigned to a different office and supervisor, his suspension was shortened, and he received reimbursement for lost wages attributable to the suspension reduction. The agreement also stated that Garrison released the department, the State of Minnesota, and their agents, officers, and employees from claims relating to the disputed matters.

Report and Recommendation and objections

United States Magistrate Judge Hildy Bowbeer recommended granting defendants’ motion for summary judgment. Summary judgment is a decision ending a claim when the evidence shows that no genuine dispute of important fact requires a trial. Garrison objected, challenging the settlement agreement’s validity and arguing that he had evidence supporting his claims.

The district court reviewed the portions of the recommendation that Garrison specifically challenged without deferring to the magistrate judge’s legal conclusions. The court also considered Garrison’s supplemental objections, although they were filed after the stated deadline, because defendants had an opportunity to respond.

Settlement release

Applying Minnesota law, the court treated the settlement agreement as a contract. It explained that settlement agreements releasing claims are generally presumed valid. A party challenging a release must show either that the party did not intend to release the claims or that the agreement lacked sufficient consideration, meaning something of value exchanged in support of the agreement.

The court agreed that Garrison intentionally and willingly entered the agreement. The release language was clear, Garrison was represented by two union representatives during negotiations, and the record contained no evidence that coercion or duress caused him to sign.

The court also held that the agreement was supported by sufficient consideration. Garrison received a new supervisor, a shorter suspension, reimbursement for lost wages and accruals, and conversion of his disciplinary demotion to a voluntary demotion. The court rejected Garrison’s argument that consideration had to be provided on the same day the agreement was signed. It also rejected his argument that revisions proposed by him were conditions precedent rather than consideration.

Remaining retaliation theory

The court recognized that the release did not resolve Garrison’s contention that the department retaliated against him by implementing the settlement agreement, including by reassigning him and reducing his salary. Because Garrison did not specifically object to the recommendation on that point, the court reviewed it for clear error. The court found no clear error and agreed that Garrison had not produced evidence creating a genuine dispute of material fact concerning that retaliation theory.

Disposition

The court overruled Garrison’s objections, adopted the March 8, 2019 Report and Recommendation, and granted defendants’ motion for summary judgment. The order directed that judgment be entered accordingly.