Hillesheim v. Wells Fargo Bank, N.A.

Background

Gregory Hillesheim, a former Wells Fargo employee, alleged that Wells Fargo violated the Minnesota Human Rights Act (MHRA) by terminating his employment because of his disability or age. His amended complaint asserted disability-discrimination and age-discrimination claims. Wells Fargo moved for summary judgment, which asks whether the evidence shows that no genuine dispute of important fact requires a trial and that the moving party is entitled to judgment as a matter of law.

Hillesheim suffered a heart attack at work in 2015, spent a weekend in the hospital, and returned to work three days later. He testified that the heart attack did not affect his ability to work or perform major life activities, that he never requested an accommodation, and that he did not consider himself disabled. In 2018, he entered a fabricated $50,000 account into Wells Fargo’s mortgage software to determine whether a customer would qualify for a mortgage-related letter. Wells Fargo terminated him on March 25, 2019, for submitting false information. Afterward, some of his business was transferred to Jan Struss, who was five years younger and already worked for Wells Fargo in the same job.

Disability-discrimination claim

The court applied the burden-shifting framework used for MHRA discrimination claims. Under that framework, the employee must first provide evidence supporting an initial discrimination case, after which the employer must identify a legitimate, nondiscriminatory reason for its action. The employee then must provide evidence that the stated reason was a pretext for discrimination.

The court held that Hillesheim had not shown that he was disabled under the MHRA. The statute’s relevant definition requires a physical, sensory, or mental impairment that materially limits one or more major life activities. Hillesheim testified that his heart attack caused no such limitations, and the record contained no medical or other evidence showing otherwise. The court also concluded that a one-time health incident followed by a quick recovery and no missed work did not establish a disability on this record.

The court therefore concluded that no reasonable jury could find that Hillesheim was disabled and held that Wells Fargo was entitled to summary judgment on the disability-discrimination claim.

Age-discrimination claim

The court also applied the burden-shifting framework to the age-discrimination claim. The parties did not dispute that Hillesheim was within the protected age group, qualified for his position, and suffered termination. They disputed whether he was replaced by a younger employee, an element of the initial discrimination case under the standard applied by the court.

The court held that Struss did not replace Hillesheim. Struss was already a Wells Fargo employee, had been transferred to the Eagan branch before Hillesheim’s termination, and was performing the same job when Hillesheim was terminated. The record showed that some of Hillesheim’s work was redistributed, not that Struss was hired or reassigned to replace him. The court further stated that, even if Hillesheim had shown replacement, Struss was only five years younger, which was insufficient under the authority the court applied to establish the initial age-discrimination case.

Disposition

The court concluded that no genuine dispute of material fact existed and that no reasonable jury could find for Hillesheim on either claim. Judge Wilhelmina M. Wright granted Wells Fargo Bank, N.A.’s motion for summary judgment, and the order directed that judgment be entered accordingly.