Lieffring v. Prairieland Solid Waste Facility

Background

The defendants—Prairieland Solid Waste Facility, County of Martin, and County of Faribault—filed several motions asking the court to exclude evidence or testimony. The motions addressed evidence about issues previously decided by the court, a discovery dispute that remained before the magistrate judge, disabilities that James Lieffring had not disclosed in discovery, and Plaintiff’s Exhibit 52, a photograph of Lieffring and his family.

The court noted that it had previously granted Prairieland’s motion for partial summary judgment on Counts II, III, and V. Lieffring also voluntarily dismissed the claim for intentional obstruction of workers’ compensation benefits in Count VI. The court had already granted Lieffring’s motion to exclude the dismissed counts from consideration.

Rulings on the Motions

Evidence about previously decided issues

The defendants sought to exclude evidence that the Counties and Prairieland were joint or integrated employers under Count I. Because the court had previously ruled that Lieffring could introduce that evidence, it denied this part of the motion.

The defendants also argued that Lieffring should not be allowed to dispute whether the ability to lift 35 pounds was an essential function of a Prairieland Production Worker’s job. The court explained that essential-function questions are usually decided by the fact-finder, but found no genuine dispute here because Lieffring had not presented evidence disputing that the requirement was essential. The parties instead disputed whether he could meet the requirement using his uninjured arm. The court held that Lieffring could present evidence that he could lift 35 pounds with his right arm and denied this part of the motion as moot.

The order therefore states that the motion concerning previously decided issues was DENIED and DENIED as moot.

Testimony relating to unresolved discovery

The defendants asked the court to exclude evidence relating to a discovery dispute then pending before the magistrate judge. The court deferred ruling on that motion until the discovery was complete.

Evidence of disabilities other than those disclosed in discovery

The defendants sought to exclude evidence of disabilities beyond Lieffring’s rotator cuff injury from January 30, 2018. Lieffring argued that he had also alleged violations of the Family and Medical Leave Act, or FMLA, and the Minnesota Human Rights Act, or MHRA, based on a disability arising from a mesenteric artery blockage on November 19, 2017.

The court found that Lieffring had alleged FMLA violations in Count I relating to both disabilities. It therefore denied the motion as to Count I.

The court reached a different conclusion for Count IV. It found that Lieffring’s discovery answer identified only his left-shoulder rotator cuff tear as the disability supporting his MHRA claim. The court concluded that Count IV was limited to that shoulder injury and granted the motion as to Count IV.

Exhibit 52

The defendants sought to exclude Exhibit 52, a photograph of Lieffring and his family. Lieffring’s counsel submitted an affidavit asserting that Lieffring could establish a proper foundation for the photograph. The court denied the motion to exclude Exhibit 52.

Disposition

Judge Susan Richard Nelson ordered that the motion concerning previously decided issues was DENIED and DENIED as moot; the motion concerning unresolved discovery was DEFERRED; the motion concerning other disabilities was DENIED as to Count I and GRANTED as to Count IV; and the motion to exclude Exhibit 52 was DENIED. This order resolved evidentiary motions and did not itself enter a final merits judgment on the underlying claims.