Minn. SC rules for employer in pregnancy discrimination case

By Zachary Lewis | Apr 18, 2017

MINNEAPOLIS (Legal Newsline) – The Minnesota Supreme Court on April 5 reversed a Court of Appeals judgment in a case involving pregnancy and sex discrimination.

The plaintiff, Nicole LaPoint, had sued Family Orthodontics PA after its owner, Dr. Angela Ross, rescinded a job offer she made to LaPoint after discovering she was pregnant.

LaPoint applied for a vacant orthodontic assistant position at Family Orthodontics on the recommendation of a friend. She interviewed with Ross on March 22, 2013. During the interview, LaPoint’s pregnancy was not discussed nor was the topic brought up.

Two days later, Ross offered the job to LaPoint, leaving a message on her voicemail. LaPoint informed Ross of her pregnancy and a planned birth in October upon calling her to accept the position. Ross and LaPoint discussed her continued employment after giving birth and the potential length of her maternity leave. 

LaPoint wished for 12 weeks but was willing to compromise as Ross explained the practice’s policy of leave allowance was six weeks.

Ross had called LaPoint the following day leaving a message expressing she “did not sleep very well” the previous night due to areas of concern with hiring LaPoint, court documents state. Ross stated her confusion as to why LaPoint failed to have mentioned her pregnancy during the interview. 

She also mentioned how detrimental it would be to her practice should LaPoint receive 12 weeks of leave as a new hire. After a series of back and forth correspondence by email, Ross ended up hiring an intern who previously worked at the practice in May 2013.

Ross’ actions prompted LaPoint to file a lawsuit under the Minnesota Human Rights Act (MHRA). LaPoint stated she had been discriminated against because of her sex and claimed Ross had rescinded her offer due to the pregnancy. 

After a bench trial, the district court judge ruled that Ross had committed no acts of discrimination and opined LaPoint failed to prove she was overlooked for the position due to her being pregnant, despite her evidence of voicemails, emails, and handwritten notes. 

The court stated, based on her testimony, Ross’ primary reason she wasn’t hired was the 12-week maternity leave LaPoint alluded to, deciding the long absence could hinder her practice if she were hired.  

After filing a motion for judgment as a matter of law, which the district court denied, LaPoint appealed the decision.

The Court of Appeals overturned the judgment made by the district court, quoting Ramlet v. E.F. Johnson Co. as to the use of the term “specific link” as a basis and used an alternative “’direct-evidence’ method”, i.e. evidence that showed a “specific link” between LaPoint’s pregnancy and Ross’ refusal to hire her. 

The court also stated Ross’ reasoning for withdrawing the job offer was the maternity leave and the fact it is related to the pregnancy is a "chicken or egg" argument.

Moreover, according to Minnesota Statue, employers are prohibited from requiring or requesting information related to an applicant’s sex and the court concluded as her pregnancy would have never been brought up by Ross under the law, her omission of this fact was deemed “illegitimate” as a reason for concern.

Family Orthodontics appealed to the Supreme Court, which said the standards used in the Court of Appeals decision were incorrect.

The plaintiff must prove the employer’s actions were “actually motivated” by a “protected characteristic," the court ruled. 

As LaPoint had argued Ross’ reasons were evidence of discriminatory motives, the Supreme Court referred back to the district court records that had found Ross’ withdrawal of the offer was based her concern for LaPoint's potential time of absence. The court stated the district court found no animosity in her testimony and emphasized Ross only questioned why LaPoint’s pregnancy was not introduced when they first met.

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