Willman v. Farmington Area Public School District

Background

Mary Willman was a special education teacher employed by the Farmington Area Public School District. Megan Blazek was the principal at Willman’s school. After performance concerns during the 2018–2019 and 2019–2020 school years, the District placed Willman on probation, developed a performance improvement plan, investigated additional concerns, and terminated her employment. The School Board voted to discharge her on February 10, 2020.

Willman had taken medical leave under the Family and Medical Leave Act (FMLA) for surgery related to a hand injury. Her initial six-week leave was approved and later extended through January 12, 2020. She also pursued workers’ compensation benefits. The District relied on performance-related reasons for the termination, including concerns about student supervision, individualized instruction, special-education paperwork, communication with families and teachers, supervision of paraprofessionals, and implementation of classroom procedures.

After an earlier dismissal order, the remaining claims were FMLA interference, FMLA retaliation, workers’ compensation retaliation, defamation, and disability discrimination under the Americans with Disabilities Act (ADA). The defendants moved for summary judgment, which is a ruling without a trial when the court finds no genuine dispute over facts that could affect the result.

Rulings on the FMLA Claims

The court granted summary judgment on the FMLA interference claim. The parties agreed that Willman was eligible for FMLA leave and that the District knew she needed it. Although Willman argued that Blazek initially delayed signing her leave paperwork, required her to find a substitute, and asked for an exact return date, the court held that Willman ultimately received all the leave she requested. Even assuming the delay was a denial, Willman did not show that it caused legally relevant harm.

The court also granted summary judgment on the FMLA retaliation claim. The court found that Willman did not provide direct evidence linking her FMLA request to her termination. Under the indirect-evidence framework, the court concluded that the timing was too long to establish the required connection and that the District provided facially legitimate, nondiscriminatory reasons for terminating her. Willman did not present sufficient evidence that those reasons were a pretext—a false explanation used to conceal unlawful retaliation.

Workers’ Compensation Retaliation

The court granted summary judgment on Willman’s workers’ compensation retaliation claim. The court treated her December 17, 2019, workers’ compensation claim petition as the relevant protected activity, but found that the period between that petition and the District’s January 28, 2020, decision to move toward termination was too long to establish causation. The court also held that Willman did not present sufficient evidence that the District’s performance-related reasons were pretextual.

Defamation

The court denied summary judgment on the defamation claim based on statements made to the School Board and Superintendent. Under Minnesota law, defamation requires a false statement communicated to someone other than the plaintiff that tends to harm the plaintiff’s reputation. Willman presented evidence that some information provided to the Board may have been false or misleading, including information about her evaluations, student supervision procedures, and whether she implemented suggestions from an experienced teacher.

The court also found factual disputes about whether District employees knew some statements were false and whether they acted with actual malice, meaning ill will or an improper motive. Because those disputes could affect the result, the court held that the claim was suitable for a jury. The court exercised supplemental jurisdiction, allowing it to decide the related state-law defamation claim even after disposing of the federal claims.

The court granted summary judgment on the portion of the defamation claim based on the District’s submission to the Minnesota Professional Educator Licensing and Standards Board because Willman presented no evidence that the submission was made with ill will or an improper motive. The court also granted summary judgment on statements to the Equal Employment Opportunity Commission because Willman chose not to pursue that part of her claim.

ADA Claim and Disposition

The court granted summary judgment on Willman’s remaining ADA disability-discrimination claim against Blazek because Willman had not continued to prosecute it. The court’s order therefore granted in part and denied in part the defendants’ motion for summary judgment: it granted the motion on the FMLA interference and retaliation claims, the workers’ compensation retaliation claim, and the ADA discrimination claim; it denied the motion on the defamation claim based on statements to the School Board and Superintendent. The case was placed on the court’s next trial calendar.