Oberthien v. CRST Logistics, Inc.
| Decision Date | 24 March 2017 |
| Docket Number | No. 15-CV-128-LRR,15-CV-128-LRR |
| Parties | RYAN OBERTHIEN, Plaintiff, v. CRST LOGISTICS, INC., CRST INTERNATIONAL, INC., and AMANDA PIERCE, Defendants. |
| Court | U.S. District Court — Northern District of Iowa |
TABLE OF CONTENTS
I. INTRODUCTION ....................................... 2
II. PROCEDURAL HISTORY ................................ 2
III. SUBJECT MATTER JURISDICTION ......................... 2
IV. SUMMARY JUDGMENT STANDARD ......................... 2
V. RELEVANT FACTUAL BACKGROUND ....................... 3
VI. ANALYSIS ........................................... 9
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 ().
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 all other facts immaterial.'" B.M. ex rel. Miller v. S. Callaway R-II Sch. Dist., 732 F.3d 882, 886 (8th Cir. 2013) (alteration omitted) (quoting Celotex, 477 U.S. at 322-23).
V. RELEVANT FACTUAL BACKGROUND
Viewing the evidence in the light most favorable to Oberthien and affording him all reasonable inferences, the uncontested material facts are as follows.
In June or July of 2013, Oberthien became employed with CRST as a capacity executive. "CRST Statement of Undisputed Facts in Support of Motion" ("CRST Facts") (docket no. 13-2) ¶ 3; "CRST Appendix in Support of Motion" ("CRST App'x") (docket no. 13-3) at 8.1 When Oberthien began working at CRST, he initially reported to capacity region manager Tom Lower. CRST App'x at 8.
Upon commencing his employment with CRST, Oberthien received a copy of CRST's employee handbook. CRST Facts ¶ 4; CRST App'x at 14; see also CRST App'x at 28-49. The employee handbook identifies "[e]xcessive absenteeism or any absence without notice" as a violation subject to disciplinary action and provides that "[d]isciplinary actions are generally progressive." Id. at 29-30. The employee handbook also describes CRST's leave of absence policy, which provides for twelve weeks (equivalent to 480 hours) of leave time to FMLA-eligible employees. Id. at 41. The handbook encourages employees to contact a human resources representative if they receive unfair treatment due to their use of FMLA leave, or if they are harassed or discriminated against due to a disability. Id. at 42, 45.
In February of 2014, Oberthien's daughter was diagnosed with cancer. CRST Facts ¶ 5; CRST App'x at 8. Due to his daughter's condition, CRST approved Oberthien for 480 hours of FMLA leave. CRST Facts ¶ 10; CRST App'x at 9, 186-192. Oberthien's FMLA leave was structured to allow him to use his leave time whenever the need arose, rather than for an unbroken twelve-week period. See, e.g., CRST App'x at 8 (); id. at 15 (); id. at 122 (). Oberthien's 480-hour allotment applied to the twelve-month period from February of 2014 through February of 2015, at which point Oberthien could be eligible for an additional 480 hours. See, e.g., CRST Facts ¶ 10; CRST App'x at 87 (); id. at 192 (referring to "a 'rolling' 12-month period"). Oberthien was expected to provide his manager with timely notice whenever he planned to use FMLA leave. CRST Facts ¶¶ 16, 19, 37; CRST App'x at 15, 112.
By October 31, 2014, Oberthien had taken 492 hours of FMLA leave, exceeding his initial allotment by twelve hours. CRST Facts ¶ 26; CRST App'x at 69. Due to Oberthien's early exhaustion of his 480-hour period, CRST approved him for 80 additional hours. CRST Facts ¶ 26; CRST App'x at 69. By December 17, 2014, Oberthien had approximately 30 hours remaining of the supplemental 80-hour period. CRST App'x at 70. On that date, CRST informed Oberthien that "an administrative separation of employment may be necessary" if he exhausted the 80-hour period before his FMLA eligibility reset. CRST Facts ¶¶ 18, 32; CRST App'x at 70. CRST further informed Oberthien that, if an administrative separation became necessary, it would implement a "catastrophic policy" to provide Oberthien with a post-separation stipend to assist with his daughter's health care costs. CRST Facts ¶ 32; CRST App'x at 70. By December 31, 2014, Oberthien had only 15 hours remaining of the supplemental 80-hour period. CRST Facts ¶ 35; CRST App'x at 87. CRST reminded Oberthien that an administrative separation, with catastrophic policy, may be necessary if he exhausted his hours. CRST Facts ¶ 35; CRST App'x at 87. Oberthien did not exhaust his remaining hours—his FMLA eligibility reset in February of 2015 and no administrative separation occurred. "Oberthien Appendix of Documents Supporting Resistance" ("Oberthien App'x") (docket no. 14-3) at 14.
In September of 2014, Oberthien was reassigned to capacity region manager Amanda Pierce. CRST Facts ¶ 13; CRST App'x at 10, 112. Oberthien and Pierce developed a system whereby, on any given day, Oberthien was expected to notify Pierce by 7:00 a.m. via text message if he expected to be tardy or absent from work. CRST Facts ¶¶ 19, 37; CRST App'x at 24, 67, 112-13. On several occasions, Oberthien failed to timely notify Pierce about his tardiness and/or absences—some of which were not related to his daughter's medical treatment. CRST Facts ¶¶ 28, 33, 34, 36, 38, 40; see also CRST App'x at 72-73, 85. Oberthien apparently had similar issues when he worked under Lower, but he was never confronted about them. Cf. Oberthien App'x at 12. However, Pierce regularly confronted Oberthien about his notification issues, reminded him of her expectations and, on one occasion, initiated disciplinary action against him. CRST Facts ¶¶ 27, 30,...
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