Barbara Henry, Respondent/Cross-Appellant, vs. Independent School District #625, a/k/a Saint Paul Public Schools, Appellant/Cross-Respondent., 988 N.W.2d 868

Summary

HOLDINGS: [1]-The court of appeals properly determined summary judgment was proper on an employee's hostile work environment claim under the Minnesota Human Rights Act, Minn. Stat. § 363A.08, subd. 2(2)-(3) (2022), because a school district's conduct was not sufficiently severe or pervasive when viewed in the light most favorable to the employee; [2]- The employee established a genuine issue of material fact as to whether she suffered an adverse employment action in the form of constructive discharge. She presented evidence that demonstrated school district management took a number of deliberate steps calculated to make herworking environment unbearable so that she would resign. A jury could find that a reasonable person faced with an unachievable performance improvement plan based on performance reviews consisting of trivial and exaggerated allegations would feel compelled to resign.