Schmidt v. University of Northwestern-St Paul

Background

Rolanda Schmidt sued the University of Northwestern-St. Paul (UNW) and four employees—Philip Vierling, David Erickson, Tanya Grosz, and Sue Johnson. She alleged that defendants discriminated and retaliated against her because of her race, gender, and age, creating a hostile work environment and contributing to her termination in June 2018.

The complaint asserted claims under Title VII of the Civil Rights Act, the Age Discrimination in Employment Act, and 42 U.S.C. § 1983, along with a state-law negligent-supervision claim. The Section 1983 claim was brought against the individual defendants. The defendants removed the case from state court and moved to dismiss, arguing that the ministerial exception, laches, and other grounds barred the claims. Schmidt defended her Title VII and negligent-supervision claims but voluntarily waived her Age Discrimination in Employment Act and Section 1983 claims.

Court’s analysis

The court applied the Rule 12(b)(6) standard, which asks whether the complaint contains enough factual allegations to state a plausible claim for relief. The court found that Schmidt’s Title VII and negligent-supervision allegations met that standard. The defendants did not challenge whether those claims were plausibly pleaded.

The court declined to decide at the dismissal stage whether the ministerial exception applied. That exception is a defense based on the First Amendment’s religion clauses that can prevent courts from interfering with certain employment disputes involving religious institutions and employees performing religious functions. The court recognized that UNW is a Christian university and that its mission statements described an important religious role for faculty members. But the defendants relied primarily on those statements and did not provide enough facts about Schmidt’s actual duties, such as whether she provided religious instruction or led students in religious activities. The court therefore found the issue fact-intensive and premature to resolve with the information then available.

The court also declined to apply laches to dismiss the Title VII claim. Laches is an equitable defense based on an unreasonable and inexcusable delay that prejudices the opposing party. The court concluded that the reasonableness of Schmidt’s delay and any resulting prejudice depended on facts that had not been fully developed. It also noted that the delay was shorter than delays in some cases where laches applied, and that UNW relied on a Minnesota 31-month rule without providing additional evidence of prejudice. The court stated that discovery was appropriate for determining whether the delay was unreasonable and prejudicial.

Disposition

The court ordered that defendants’ Motion to Dismiss was DENIED in part and GRANTED in part. It denied the motion as to Schmidt’s Title VII and negligent-supervision claims because it was premature to decide the ministerial-exception and laches defenses. It granted the motion as to Schmidt’s voluntarily waived Age Discrimination in Employment Act and Section 1983 claims.

Because the Section 1983 claim was the only claim naming Vierling, Erickson, Grosz, and Johnson as defendants, those four individuals were dismissed from the case. UNW remained as the only defendant moving forward. Judge John R. Tunheim signed the order on February 7, 2024.