Davis v. CoreLogic Platinum Valuation Services, LLC

Background

John Davis sued CoreLogic Platinum Valuation Services, LLC under the Minnesota Human Rights Act (MHRA), claiming age discrimination. Davis was 57 in November 2020 and had worked as a residential real estate appraiser for CoreLogic or related entities since December 2006. He resigned after receiving fewer appraisal assignments than Callie Saumweber, whom the opinion describes as 14 years younger than Davis. Davis claimed that the imbalance reduced his commissions and amounted to a constructive discharge—meaning that the employer deliberately made working conditions so intolerable that a reasonable employee would feel forced to quit.

Appraisal assignments were distributed through CoreLogic’s automated system. Each appraiser had daily and overall capacity settings that affected eligibility for assignments. In April 2020, an operations-team member increased Saumweber’s daily capacity to allow a specific appraisal to be assigned to her, but the setting was not restored afterward. The court found that this mistake caused the system to favor Saumweber when assigning work. The setting was equalized on November 18, 2020, after CoreLogic investigated Davis’s concerns, but Davis was not told about the change before he resigned on November 20.

CoreLogic initially attributed Saumweber’s higher capacity to her work supervising a trainee. During litigation, Scott Nicholson discovered that the capacity increase had instead resulted from the April manual adjustment. The court found that both explanations were nondiscriminatory explanations for an error, rather than evidence that CoreLogic intentionally manipulated assignments because of Davis’s age.

Legal Standard and Parties’ Positions

CoreLogic moved for summary judgment under Federal Rule of Civil Procedure 56. Summary judgment is appropriate when the evidence shows no genuine dispute about a fact that could affect the result and the moving party is entitled to judgment as a matter of law. The court viewed the evidence in the light most favorable to Davis.

For Davis’s MHRA claim, the court applied the framework used for circumstantial age-discrimination claims. Davis first had to establish a preliminary case of discrimination, including that he was constructively discharged. He then would have had to show that CoreLogic’s stated nondiscriminatory reason was a pretext, meaning a cover for intentional discrimination.

Davis argued that CoreLogic created a hostile environment for older workers, that a manager had asked about his age and how long he planned to work, and that the differing explanations for Saumweber’s capacity setting showed that CoreLogic deliberately forced him out. He also argued that CoreLogic should have discovered and corrected the capacity problem earlier and should have told him about the correction immediately.

CoreLogic argued that the assignment imbalance was an inadvertent capacity-setting mistake. It also argued that Davis had not shown intolerable working conditions or deliberate conduct intended to force his resignation.

Court’s Analysis

The court held that Davis failed to show a constructive discharge. First, Davis did not establish that the assignment imbalance created conditions that a reasonable person would find intolerable. The court explained that dissatisfaction with work assignments and loss of pay generally do not, by themselves, establish constructive discharge. Davis’s financial circumstances also did not establish intolerable working conditions under the governing standard.

Second, Davis did not present evidence that CoreLogic deliberately made his working conditions intolerable to force him to quit. The capacity error occurred in April, before Michael McKinney became Davis’s manager in August. The court found no evidence that anyone intentionally created the imbalance. It also noted that Davis had not told McKinney that he was receiving fewer assignments than Saumweber, had not reported a capacity imbalance to Clay Vescera, and had not mentioned discrimination when first raising his concerns with management and human resources.

The court rejected Davis’s argument that the company’s differing explanations demonstrated pretext. It found that CoreLogic’s explanations were consistent in identifying an error as the cause of the imbalance. The court also found that CoreLogic investigated Davis’s complaint and corrected the capacity settings when the problem was discovered. Although the correction was not immediately communicated to Davis, the court found no evidence that the delay was motivated by age discrimination.

Because Davis failed to establish constructive discharge, the court held that he did not establish a preliminary case of age discrimination. The court further held that, even assuming he had established that preliminary case, CoreLogic had offered a legitimate, nondiscriminatory explanation and Davis had not shown that explanation was a pretext for intentional discrimination.

Disposition

Judge Michael J. Davis granted Defendant CoreLogic Platinum Valuation Services, LLC’s Motion for Summary Judgment. The order directed that judgment be entered accordingly.