Plaintiff Matthew Meinen sued defendant Bi-State Development Agency in the United States District Court for the Eastern District of Missouri, raising claims of discrimination based on race and gender, hostile work environment, and retaliation. The district court dismissed Meinen’s claims, and Meinen appealed the decision to the United States Court of Appeals for the Eighth Circuit.
Factual Overview
Matthew Meinen, a white male, worked as a Transit Security Specialist Lead for Bi-State Development Agency. In early 2021, Meinen began experiencing harassing behavior from an unidentified female African American Transit Security Specialist employee. Meinen reported several incidents to his supervisor and the female employee’s supervisor, including occasions when the female employee intentionally rubbed her backside on him, blocked his path in the hallway, and made inappropriate comments. In March 2021, Meinen was interviewed by a Bi-State human resources employee as part of an unrelated investigation. Following the employee’s suggestion, Meinen prepared a written disciplinary warning and delivered it to the female employee. Approximately one to two months later, Meinen was terminated. Meinen filed a claim with the Equal Employment Opportunity Commission (EEOC) and, after receiving a right to sue letter, commenced an action in Missouri state court, which Bi-State removed to federal court.
Legal Analysis
Retaliation Claim: The Eighth Circuit affirmed the dismissal of Meinen’s retaliation claim, finding that he did not plead sufficient facts to give rise to an inference of causation beyond mere speculation. The court noted that while temporal proximity can be sufficient to establish a causal connection, Meinen’s complaint relied solely on the one to two-month gap between his protected activity and termination without alleging additional facts to support a retaliatory motive.
Discrimination Claims: The Eighth Circuit found that the district court properly applied the McDonnell Douglas framework to evaluate Meinen’s allegations of discrimination. The court determined that Meinen’s race and gender discrimination claims were insufficient to give rise to an inference of discrimination, as they relied solely on his allegation that an unidentified African American female filed an unrelated complaint against another white male, without alleging that the unrelated investigation involved similarly situated individuals or conduct.
Hostile Work Environment Claim: The Eighth Circuit affirmed the dismissal of Meinen’s hostile work environment claim, finding that although Meinen alleged behavior by a co-worker that made him uncomfortable, the alleged conduct failed to show the type of extreme behavior that would entitle him to relief.
Dissenting Opinion: Judge Grasz concurred with the majority’s decision to affirm the dismissal of Meinen’s race discrimination, gender discrimination, and hostile work environment claims but dissented from the majority’s decision to affirm the dismissal of Meinen’s retaliation claim. Judge Grasz argued that under Eighth Circuit precedent, the close temporal proximity between Meinen’s protected activity and his termination was sufficient to infer retaliation at the pleading stage. The dissent also noted that Meinen pled additional facts showing why retaliation was a plausible but-for cause of his termination, such as Bi-State never investigating his allegations of harassment and his long tenure with the company.
The Eighth Circuit affirmed the district court’s dismissal of all of Meinen’s claims.
(Author note: Pacer searches were unsuccessful on finding this case. I was able to download it from the Eighth Circuit’s daily opinion page, but I cannot find this case by searching for either it’s name (the link takes you to a different case) or its number.)
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