Latest 2 Cases: CRST Expedited, Inc. v. Transam Trucking, Inc. (Business Law), Findlator v. Allina Health Clinics (Civil Rights)

Before She Died, “Jane Roe” Said She Was Never Really Pro-Life: Does It Matter?

MICHAEL C. DORF

Cornell law professor Michael C. Dorf comments on the revelation that before she died, Norma McCorvey—the woman who was the plaintiff in Roe v. Wade and who had subsequently become a prominent spokesperson for overturning the decision—said she was never really pro-life after all. Using this example, Dorf explains why, in some ways, the individual plaintiff’s identity does not matter for the purpose of deciding an important legal issue, yet in other ways, the plaintiff’s underlying story can be very important for other reasons.

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CRST Expedited, Inc. v. Transam Trucking, Inc.

Dockets: 18-2633, 18-2752

Opinion Date: May 27, 2020

Judge: Bobby E. Shepherd

Areas of Law: Business Law, Contracts

CRST filed suit against TransAm, alleging that TransAm wrongfully recruited and hired several long-haul truck drivers who were under contract with CRST. The district court granted TransAm's motion for summary judgment and dismissed all of CRST's claims with prejudice. The Eighth Circuit held that the district court erred with respect to the causation element but did not err with respect to the existence of a valid contract element, and that the record contains sufficient evidence to support the intentional and improper interference element. The court also held that the district court erred in granting TransAm's motion for summary judgment on CRST's unjust enrichment claim. Finally, the court held that the district court did not abuse its discretion in finding the drivers were not indispensable parties. Accordingly, the court reversed and remanded the district court's order granting TransAm's motion for summary judgment and affirmed the district court's determination that the drivers are not indispensable parties to the proceedings.

Findlator v. Allina Health Clinics

Docket: 19-1142

Opinion Date: May 27, 2020

Judge: Erickson

Areas of Law: Civil Rights, Constitutional Law, Labor & Employment Law

Plaintiff filed suit against her former employer, Allina, for race and national origin discrimination as well as intentional infliction of emotional distress. The Eighth Circuit affirmed the district court's grant of summary judgment as to the discrimination claims, holding that the record demonstrates that Allina considered plaintiff's race only to ensure that any corrective action was not based on racial discrimination; without direct evidence of discrimination, the court relied on the burden shifting McDonnell Douglas analysis; and, assuming plaintiff established a prima facie case, plaintiff failed to demonstrate that Allina's stated reason for terminating her was pretext. The court explained that nothing in Allina's Violence-Free Workplace policy or other policies prohibit Allina from treating some offenses as more severe than others and selecting a corrective action that it believes is proportional to the level of severity for the violation. In this case, Allina's response to plaintiff's grievance and the deposition of an Allina human resources director make clear that Allina believed that pushing a coworker was more severe than throwing a lab coat at a co-worker and that plaintiff's behavior justified a more severe punishment.