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Oberthien v. CRST Logistics, Inc.

United States District Court, N.D. Iowa, Cedar Rapids Division

March 24, 2017

RYAN OBERTHIEN, Plaintiff,
v.
CRST LOGISTICS, INC., CRST INTERNATIONAL, INC., and AMANDA PIERCE, Defendants.

          TABLE OF CONTENTS

          LINDA R. READK JUDGE.

         I. INTRODUCTION ....................................... 2

         II. PROCEDURAL HISTORY ................................ 2

         III. SUBJECT MATTER JURISDICTION ......................... 2

         IV. SUMMARY JUDGMENT STANDARD ......................... 2

         V. RELEVANT FACTUAL BACKGROUND ....................... 3

         A. Employment and FMLA Leave .......................... 4

         B. Conflict with Management ............................. 5

         C. Conclusion of Employment ............................ 7

         VI. ANALYSIS ........................................... 9

         A. Disability Discrimination .............................. 9

         1. Adverse employment action ....................... 10

         2. Pretext .................................... 12

         a. Productivity goals .........................14

         b. Justification for misconduct ..................14

         c. Treatment of other employees .................16

         B. FMLA Discrimination ...............................18

         C. Hostile Work Environment ...........................21

         VII. CONCLUSION ....................................... 24

         I. INTRODUCTION

         The matters before the court are Defendants CRST Logistics, Inc., CRST International, Inc. and Amanda Pierce's (collectively, “CRST”) “Motion for Summary Judgment” (“Motion”) (docket no. 13) and “Motion to Strike Supplement to Plaintiff's Summary Judgment Resistance” (“Motion to Strike”) (docket no. 19).

         II. PROCEDURAL HISTORY

         On October 13, 2015, Plaintiff Ryan Oberthien filed a Petition (docket no. 3) in the Iowa District Court for Linn County alleging the following claims against CRST: (1) disability discrimination in violation of the Americans with Disabilities Act (“ADA”); (2) harassment causing a hostile work environment in violation of the ADA; and (3) retaliation in violation of the Family and Medical Leave Act (“FMLA”). On November 16, 2015, CRST removed the case, bringing it before the court. See Notice of Removal (docket no. 2). On November 23, 2015, CRST filed an Answer (docket no. 5). On January 13, 2017, CRST filed the Motion. On February 3, 2017, Oberthien filed a Resistance (docket no. 14). On February 13, 2017, CRST filed a Reply (docket no. 17). On March 15, 2017, Oberthien filed a Supplement to the Resistance (docket no. 18). On March 20, 2017, CRST filed the Motion to Strike. Neither party requests oral argument and the court finds that oral argument is unnecessary. The matters are fully submitted and ready for decision.

         III. SUBJECT MATTER JURISDICTION

         The court has original jurisdiction over the claims in the Petition because they arise under the United States Code. See 28 U.S.C. § 1331 (“The district courts shall have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States.”).

         IV. SUMMARY JUDGMENT STANDARD

         Summary judgment is appropriate “if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed.R.Civ.P. 56(a). “A dispute is genuine if the evidence is such that it could cause a reasonable jury to return a verdict for either party; a fact is material if its resolution affects the outcome of the case.” Amini v. City of Minneapolis, 643 F.3d 1068, 1074 (8th Cir. 2011) (citing Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 252 (1986)).

         “The movant ‘bears the initial responsibility of informing the district court of the basis for its motion, ' and must identify ‘those portions of the record which it believes demonstrate the absence of a genuine issue of material fact.'” Torgerson v. City of Rochester, 643 F.3d 1031, 1042 (8th Cir. 2011) (en banc) (alterations omitted) (quoting Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986)). “If the movant does so, the nonmovant must respond by submitting evidentiary materials that set out ‘specific facts showing that there is a genuine issue for trial.'” Id. (quoting Celotex, 477 U.S. at 324).

         The court must view the record in the light most favorable to the non-moving party and afford it all reasonable inferences. See Schmidt v. Des Moines Pub. Sch., 655 F.3d 811, 819 (8th Cir. 2011). “Where the record taken as a whole could not lead a rational trier of fact to find for the nonmoving party, there is no genuine issue for trial, ” and summary judgment is appropriate. Ricci v. DeStefano, 557 U.S. 557, 586 (2009) (quoting Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587 (1986)). “A complete failure by the non-moving party ‘to make a showing sufficient to establish the existence of an element essential to that party's case necessarily renders ...


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