Out-of-State Employee Can’t Clear Discrimination Claims Against Minnesota Employer, 8th Circuit Rules

The U.S. Court of Appeals for the Eighth Circuit this week determined that an employee cannot bring workplace discrimination claims against her former employer under the Minnesota Human Rights Act because she doesn’t qualify as an “employee” as an out-of-state resident.

On Wednesday, the federal appellate court affirmed a summary judgment decision in favor of Medtronic USA, a health care technology company based in Minneapolis. The court agreed with the U.S. District Court for the District of Minnesota that Jan Kuklenski couldn’t bring claims against her former employer under the MHRA because she wasn’t an “employee” as defined by state law. On appeal, Kuklenski challenged the court’s interpretation of the statutory term and whether the act required an “employee” to have a physical presence in the state.

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