Walton v. Medtronic USA, Inc.

Background

Brian Walton sued his former employer, Medtronic USA, Inc., alleging employment discrimination under the Minnesota Human Rights Act based on age, race, and sex. The opinion states that the court had previously dismissed Walton’s claim under the Employee Retirement Income Security Act but allowed four state-law discrimination claims to continue. Walton moved to file a second amended complaint adding a race-discrimination claim under 42 U.S.C. § 1981.

Walton alleged that Medtronic terminated him during a company reorganization in July 2021 and transferred his sales territory to a younger Black woman who had previously reported to him. He also alleged that Medtronic had goals concerning the representation of women and people of color in leadership positions and that those goals caused his termination. Medtronic opposed the amendment, arguing that Walton’s allegations of discrimination based on race, sex, and age prevented him from claiming that race was the necessary cause of his termination.

Legal standard

Under Federal Rule of Civil Procedure 15(a)(2), courts generally should allow amendments when justice requires. A court may deny an amendment for reasons including undue delay, bad faith, prejudice, or futility. An amendment is futile if the proposed complaint could not survive a motion to dismiss for failure to state a legally plausible claim.

Section 1981 protects the right to make and enforce contracts without racial discrimination and requires a plaintiff to initially allege, and ultimately prove, that the alleged racial discrimination was a “but-for” cause of the loss of a legally protected right. The court explained that this means the plaintiff must allege that the result would have been different but for race. It does not necessarily mean that race must have been the only cause.

Analysis

The court held that allegations of multiple types of discrimination do not defeat a § 1981 race-discrimination claim at the pleading stage. Relying in part on the reasoning that an event may have multiple but-for causes, the court concluded that Walton could allege that age, sex, and race all contributed to the termination while also alleging that, but for his race, he would not have been terminated.

The court found that Walton’s allegations plausibly suggested that he would have kept his job if he had been a person of color. In reaching that conclusion, the court treated the alleged facts as true, as required when evaluating whether a complaint would survive a motion to dismiss. The court also stated that, even if multiple discrimination theories were incompatible, Rule 8 permits alternative and inconsistent pleading.

Disposition

The court concluded that Walton’s proposed § 1981 claim was not futile and ordered that his Motion to Amend be GRANTED. The order allowed Walton to add the federal race-discrimination claim but did not resolve whether he would ultimately prevail on that claim. The opinion was signed by John F. Docherty, United States Magistrate Judge.