Lopez Prater v. Trustees of the Hamline University of Minnesota

Background

Erika López Prater taught a World Art class at Hamline University during the Fall 2022 semester. Her employment was covered by a collective bargaining agreement (CBA) between Hamline and the Service Employees International Union Local 284. During a class on Islamic art, López Prater showed two paintings depicting the Prophet Muhammad. The complaint alleged that a Muslim student was offended, that Hamline officials criticized the incident, and that Hamline later canceled the spring course López Prater had been scheduled to teach and did not renew her contract.

López Prater’s current complaint asserted claims involving religious discrimination, reprisal under the Minnesota Human Rights Act, breach of contract, promissory estoppel, defamation, intentional infliction of emotional distress, and retaliation under the Minnesota Whistleblower Act. Hamline removed the case from Minnesota state court, arguing that federal labor law completely preempted the state-law claims because resolving them required interpreting the CBA. López Prater moved to remand the case to state court, and Hamline moved to dismiss under Rule 12(b)(6), which tests whether a complaint states a legally sufficient claim.

Remand and federal jurisdiction

The court denied López Prater’s motion to remand. It explained that federal labor law can completely preempt a state-law claim when the claim depends on interpreting a CBA. The court concluded that at least one of López Prater’s claims—particularly her religious-discrimination claim—required analysis of CBA provisions addressing Hamline’s authority over appointments, academic freedom, employment standards, and related matters. The court also found that other allegations, including claims concerning reprisal, whistleblower retaliation, academic freedom, due process, and the timing of nonrenewal, implicated CBA provisions. Because one preempted claim was enough to create federal-question jurisdiction over the case, the court held that Hamline properly removed the action and denied remand.

Religious-discrimination claim

The court denied dismissal of López Prater’s Minnesota Human Rights Act claim for religious discrimination. She advanced two theories: that Hamline discriminated against her because she was not Muslim, and that Hamline discriminated against her because she did not conform to certain religious beliefs held by others concerning depictions of the Prophet Muhammad.

The court acknowledged that these were unusual theories but held that they were plausible at the pleading stage. It reasoned that the Minnesota law’s protection against discrimination because of religion could include discrimination based on not belonging to a particular religion or not conforming to a particular religious belief. The court also found that the complaint plausibly alleged Hamline knew López Prater was not Muslim and plausibly connected the nonrenewal decision to the controversy over the paintings. The court stated that López Prater might have difficulty proving the claim later, but that she did not need to prove the claim at the motion-to-dismiss stage.

MHRA reprisal claim

The court granted dismissal of López Prater’s Minnesota Human Rights Act reprisal claim. To state such a claim, she had to plausibly allege that she engaged in activity protected by the statute, suffered an adverse action, and experienced a causal connection between the two.

López Prater alleged that she engaged in protected activity when she told Dean Marcela Kostihova that excluding paintings of the Prophet Muhammad would be discriminatory because it would favor some religious views over others. The court held that this statement did not report discrimination by Hamline. Instead, it explained why López Prater believed her own prior conduct—showing the paintings—should not be considered discriminatory. Because she did not plausibly allege protected activity, the court granted dismissal of the reprisal claim.

Defamation claim

The court granted dismissal of the defamation claim. López Prater relied on statements by Hamline officials and Jaylani Hussein describing her conduct as Islamophobic, intolerant, disrespectful, or intended to provoke, offend, and hurt Muslim students.

Under Minnesota law, defamation generally requires a false statement communicated to another person that harmed the plaintiff’s reputation. Statements that are pure opinion, rather than verifiable facts, are not actionable. The court held that the statements at issue were non-verifiable opinions or rhetorical characterizations. It therefore dismissed the defamation claim without reaching Hamline’s other arguments about that claim.

Intentional-infliction-of-emotional-distress claim

The court granted dismissal of López Prater’s intentional-infliction-of-emotional-distress claim. Such a claim requires conduct that is extreme and outrageous, intentional or reckless, and the cause of severe emotional distress.

The court held that Hamline’s alleged public criticism, announcement of the nonrenewal before the end of the semester, and involvement in later publicity did not meet Minnesota’s high threshold for extreme and outrageous conduct. It also held that allegations of humiliation, embarrassment, isolation, and emotional distress were not sufficiently particularized to show the required level of severe distress. The court further noted that the alleged harm appeared to stem largely from the incident’s spread through the media and internet rather than from particular statements by Hamline officials.

Minnesota Whistleblower Act claim

The court granted dismissal of López Prater’s retaliation claim under the Minnesota Whistleblower Act. The statute protects an employee who reports a violation, suspected violation, or planned violation of law, but the reported conduct must implicate a law or legal rule.

López Prater alleged that she reported Hamline’s statements about her as defamatory. The court held that the report could not support a retaliation claim because the court had concluded that the statements were not actionable defamation, and because the report occurred after Hamline had already informed her that her contract would not be renewed. The court also rejected her arguments that later statements or the timing of the announcement independently supplied an adverse employment action. It dismissed the whistleblower-retaliation claim.

Disposition

The order denied López Prater’s motion to remand. It granted in part and denied in part Hamline’s motion to dismiss. The order expressly states that López Prater’s claims for MHRA reprisal, defamation, intentional infliction of emotional distress, and Minnesota Whistleblower Act retaliation were dismissed, while her religious-discrimination claim was not dismissed.