While deciding if an Iowa discrimination case should be heard by the court, the Eighth Circuit Court of Appeals has reiterated the U.S. Supreme Court’s opinion that anti-discrimination laws aim to protect individual employees and are not necessarily connected to differences in treatment of two or more specific groups.
The case involves a front desk clerk at an Iowa hotel who believes she was fired for not being pretty enough.
The Iowa woman, Breanna Lewis, began working for Waterloo-based Heartland Inns of America L.L.C. in July 2005. During her employment over the next 18 months, according to court records, she worked several guest services positions and received commendations from local supervisors for her work. In December 2006, she was hired full-time to work the front desk at the company’s property in Ankeny.
Lewis alleges that after Barbara Cullinan, the director of operations who had approved her promotion by phone, saw her in the position that she was identified as not being a “good fit” for the front desk due to her lack of “prettiness” and a “Midwestern girl look.” Lewis has agreed that she appears somewhat masculine, doesn’t typically apply make-up and prefers clothing that is loose fitting. When the local supervisor refused to remove Lewis from the front desk position, she was asked to resign and then told Lewis about the comments.
Cullinan required Lewis attend a secondary interview for the front desk job, which Lewis protested but did ultimately attend. The two discussed policy changes at the hotel chain, and Lewis was encouraged to offer her opinion of the changes. The termination letter Lewis received three days later indicated that she had protested the “proposed interview procedure” and that she was hostile toward the most recent policies.
Lewis subsequently filed suit against Heartland, asserting that she was terminated for not conforming to gender stereotypes, a violation of Iowa civil rights law. The company requested and received summary judgment (case dismissal) from the district court on grounds that Lewis lacked evidence proving that she was treated differently that similarly employed males in the company.
The Eighth Circuit ruled that the Iowa civil rights law was “never intended to be rigid, mechanized or ritualistic,” and then quoted the U.S. Supreme Court: “The principal focus of [the law] is the protection of the individual employee, rather than the protection of the minority group as a whole.”
Lewis, according to the appellate court, is not require to produce evidence that she was treated differently than male employees, but need only prove that her termination from Heartland was likely done due to discriminatory practices against her as an individual.
The lower court will now once again take up the question.