Dietrich v. Canadian Pac. Ltd., 536 N.W.2d 319, 324 (Minn.1995).
Aug 25, 1995OUTCOME: Landmark case decided in favor of Employer
Employee sued employer for age discrimination, reprisal, intentional infliction of emotional distress, and negligent infliction of emotional distress. The District Court, Hennepin County, Franklin J. K ... noll, J., granted summary judgment for employer, and employee appealed dismissal of discrimination claims. The Court of Appeals, 522 N.W.2d 386, John F. Thoreen, Acting J., reversed and remanded. The Supreme Court, Stringer, J., held that: (1) when job is eliminated as part of bona fide reduction-in-force (RIF), employee must make some additional showing of age animus in order to establish prima facie case of age discrimination; (2) employee's job was eliminated in RIF; (3) employee failed to make such an additional showing; (4) employee suffered no age discrimination with regard to training and hiring opportunities; and (5) employee failed to establish prima facie case of reprisal.
