Guevara v. Monogram Meat Snacks, LLC

Background

Maria Guevara worked for approximately 14 years at Monogram’s factory in Chandler, Minnesota, in several production-line roles. Her official job title was “filler/caddie.” She reported workplace injuries in April 2014 and February 2016 and filed workers’ compensation claims after both incidents. A doctor restricted her to work using only her left hand and prohibited lifting more than 5 to 10 pounds. Monogram accommodated her for approximately 18 months by assigning her only to put labels on boxes, rather than rotating her through different tasks.

On January 25, 2018, a coworker knocked a box from a pallet while Guevara was labeling boxes. Guevara said the box struck the back of her neck; the coworker said in a written statement that it brushed Guevara’s left side, while another coworker said she did not see the box hit Guevara. Monogram’s human-resources manager, Horacio Mejias, investigated and concluded that Guevara had falsified her workers’ compensation report. Monogram asserted that it terminated her employment because of that alleged dishonesty. Guevara testified that Mejias told her she was fired because she filed a workers’ compensation claim.

On March 12, 2018, Guevara gave Monogram a doctor’s note recommending three weeks of treatment at the Mayo Clinic. Guevara viewed the note as a request for leave under the Family and Medical Leave Act, but Mejias said it did not provide enough information or follow Monogram’s leave-request procedures. Monogram terminated Guevara’s employment on March 13, 2018.

Claims and analysis

The remaining disputed claims were: disability discrimination under the Americans with Disabilities Act and the Minnesota Human Rights Act (Counts I and II); retaliation under the Minnesota Workers’ Compensation Act (Count III); and interference with medical leave under the Family and Medical Leave Act (Count IV). Summary judgment is appropriate only when the evidence shows no genuine dispute about an important fact and the moving party is entitled to judgment under the law.

For Counts I and II, the court held that the parties did not dispute Guevara’s disability, and the record showed that her physical limitations substantially or materially restricted major life activities. The court also found a factual dispute about whether she could perform the essential functions of her job with a reasonable accommodation. Although Monogram argued that lifting up to 60 pounds was an essential function, Guevara had performed the job for approximately 18 months with an accommodation, and Monogram had not established that lifting 60 pounds was essential. The court also found a factual dispute about whether the box struck Guevara and whether Monogram’s dishonesty explanation was a pretext for disability discrimination. The court therefore denied summary judgment on Counts I and II.

For Count III, the court found that Guevara’s workers’ compensation claim was protected activity and that her termination was an adverse employment action. The court found a genuine dispute about whether her termination was caused by her workers’ compensation claim. It also found that a reasonable jury could view Monogram’s dishonesty explanation as pretextual if the box did strike Guevara. The court therefore denied summary judgment on Count III.

For Count IV, the court explained that an employee seeking medical leave must give the employer enough information to indicate that the employee may need leave, although the employee need not expressly invoke the Family and Medical Leave Act. The court found that a reasonable jury could conclude that Guevara’s doctor’s note gave Monogram sufficient notice of a planned three-week medical absence. Because the note was provided one day before Guevara’s termination and factual disputes remained about the reason for the termination, the court also found a dispute about whether the termination was related to her request for leave. The court therefore denied summary judgment on Count IV.

Disposition

Judge Wilhelmina M. Wright ordered that Monogram Management Services, Inc.’s motion for summary judgment be granted in part and denied in part. The motion was granted as to Counts V, VI, and VII, which Guevara had conceded, and denied as to Counts I, II, III, and IV.