Lewis V Heartland Inns: Employee Wins Dismissal Case in 8th Circuit - Essay Sample

Introduction

Lewis V Heartland Inns of America case was an appellate case that was under Eight Circuit that was passed on 22nd January 2010. The two parties in the case were a dismissed employee as the plaintiff and Heathland Inns, the former employer as the defendant. Lewis argued that she had been dismissed illegally by her former employer Heathland Inns of America. The case had earlier been heard and judged against the plaintiff. Upon hearing the case, the Eight Circuit ruled in favor of the Lewis, thus reversing and remanding the earlier judgment by the district court.

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The legal issue in the Lewis V Heartland human resource conflict is the violation of Title VII by the later while dismissing Lewis from her job. Title VII prohibits the failure to hire or to discharge any worker on the grounds of sex, race, religion, national origin, or color. In the case of the study, the plaintiff claimed that her dismissal was a result of sexual discrimination. Lewis lost her job after a series of events, where one of her superior pointed out on several occasions that she was not the best candidate for her current position because of her mode of dressing. Ms. Lewis handled the front desk in the Heartland motel. Her performance was excellent and undisputed, yet the new director complained that Ms. Lewis did not dress in a feminine manner. According to the plaintiff, she is slightly more masculine, while her manager, Stifel, describes her as looking like Ellen DeGeneres, a popular tomboy media personality. The plaintiff wore attires that loosely fitted her, including trousers and shirts meant for men. Besides, Lewis avoided wearing make-up as well as kept her hair short. Looking like a male, Lewis considered a tomboy. In Lewis's dismissal letter, the reasons for the discharge were her hostility to new policies in the company as well as refusing to take the interview. Lewis denied the charges because nobody had complained about her performance. Besides, the hotel had not taken any disciplinary action against the alleged accusation before being discharged. Lewis argued that the real reason for her dismissal was because she did not conform to sex stereotypes, thus violating the Iowa Civil Rights Act of 1965 (ICRA), Iowa Code 216.1 et seq, and Title VII of the Civil Rights Acts of 1964, 42, U.S.C. 2000e et seq.

Lewis's arguments for unconstitutional dismissal is based on several events that that acted as the factual basis for her claim. Her factual basis was mainly based on the comments by her new Director of Operation, Barbara Cullinan. Cullinan had approved Lewis for the job after receiving a positive recommendation from Stifel, Lewis manager. However, upon seeing Lewis mode of dressing, Cullinan contested to Stifel that she was not very satisfied whether Lewis fitted the front desk. Cullinan raised the subject again, a few days later, arguing that Lewis's appearance as the issue of concern. In the process, Cullinan told Stifel, by putting Lewis on the front desk, Heartland took two steps back because her way of dressing was not a stereotypical feminine. Cullinan further claimed that the plaintiff did not have a Midwestern girl's appearance. In many occasions, Cullinan had bragged about the female employee's appearance in Heathland. She claimed that these women employees should be "pretty," particularly those at the front desk. Besides, there were occasions when Cullinan advised the manager not to hire those women who were not pretty enough. Despite Cullinan about the need to be pretty to work at the front desk, the job description for the post does not indicate so. Instead, the job description for the front desk candidate states that the staff should create a conducive and welcoming environment. Besides, the roles of those working on the front desk are to receive reservations and pass information.

To get rid of Lewis from the front desk, Cullinan made arrangements to transfer her to a different night period. Stifel, however, opposed the plan to move since she was performing exceptionally well. The following week, Cullinan told Stifel to resign. Cullinan, later, went ahead with arrangements for the second interview for front desk employees by purchasing video equipment to enable her and the Human Resource Director to see the applicants before hiring them. Cullinan argued that the reason for buying the video equipment was because Heartland hotel had a specific appearance and personifications. When Lewis was invited for the second interview, she refused and questioned the legality of the procedure. After that, Cullinan asked Lewis her comments on the reasons for the companies declining performance. Three days later, Lewis was fired.

Besides, the factual basis presented by Lewis, she also gave many summary judgments of other cases that had previously been judged by the court. Examples of these summary judgments include Griffith v. City of Des Moines, 387 F.3d 733, 736 (8th Cir.2004). In the case, the court ruled that discrimination can take place in a situation where the sex of a person is a determinant feature in any human resource practice. In the case of Lewis, therefore, her sex determined the type of dress to wear, from the Cullinan's perspective. In yet another summary judgment of Price Waterhouse v. Hopkins, 490 U.S. 228, 109 S.Ct. 1775, 104 L.Ed.2d 268 (1989), the court asserted that gender labelling can lead to Title VII violation if female employees are compelled to wear sexually provocative attire at the place of work. In the Price Waterhouse case, the court found out that sexual discrimination occurred when the plaintiff was denied partnership based on her femininity. The plaintiff in the case was told that to be accepted in a partner's position; she must dress and walk-in feminine manner, apply make-up and wear ornaments, as well as style her hair. Lewis argued similar to the plaintiff in the Price Waterhouse, she was discharged not because of neither her performance nor qualification, but because of her appearance did not conform to the company's preferred feminine stereotype.

Based on the facts and evidence presented by Lewis, the court reversed and remanded the previous judgment granted in favor of the respondent by the district court. The Eighth Circuit concluded that the plaintiff had supplied adequate proofs to support her claims for sexual discrimination. As a result, on the first impression, and the reasons given by the hotel for Lewis termination was dubious and inaccurate. As a result, it was essential to remand the case for further proceeding by the lower court. The ratio decidendi in which the decision was made include mistake by the district court in Lewis v. Heartland Inns of Am., L.L.C., 585 F.Supp.2d 1046, 1059 (S.D.Iowa 2008). In the case, the court had wrongly ruled against Lewis. It claimed that Lewis was supposed to provide proof indicating that she was treated contrarily as a woman in comparison to men. According to the district court, therefore, since Lewis had not been treated differently from other males, then discrimination based on sex did not occur. The Eighth Circuit rejects that premise by citing decisions of other circuits such as Young v. Warner-Jenkinson Co., 152 F.3d 1018, 1022 (8th Cir.1998), and Bryant v. Aiken Reg'l Med. Ctrs. Inc., 333 F.3d 536, 545 (4th Cir.2003).

Additionally, the court held that the ultimate problem in the case was the motive for Lewis's ill-treatment as an individual and not the relative treatment of other groups in the hotel. In yet another example, Connecticut v. Teal, 457 U.S. 440, 453-54, 102 S.Ct. 2525, 73 L.Ed.2d 130 (1982), the court explained that Title VII aimed to protect an employee as an individual entity, but not the entire group that he belonged to. If the plaintiff had relied on comparative evidence to support her case, then the court would have required such proof. However, since comparative evidence is not an exclusive way to establish the existence of discrimination, the plaintiff has the liberty to utilize other types of evidence. Based on this ratio decidendi, the Eight Circuit found that the district court had made an error by expecting that Lewis should have proved that she was subjected to different treatment from men in the workplace.

By looking at the previous work performance records of Lewis, it is clear that Eight Circuit claims that Heartland hotel reasons for discharging her were pretextual. She had a good track record in terms of performance and had received two pay raises based on merits. Besides, before her dismissal, she had no disciplinary record. Two of her supervisors stated that her appearance had no negative impact on her performance and that Lewis often received positive compliments from customers who commend her for the exemplary service she provides. It is, therefore, most unlikely that the reasons she was fired were those stated in the termination letter. Based on the initial negative comments and directives by the Cullinan, Lewis's dismissal may be motivated by discrimination. It is, therefore, justifiable for the Eight Circuit to reverse the previous ruling by the district court, and direct more investigation and proceeding concerning the matter.

From the above discussion, it is clear that Lewis supplied adequate proof to support her claims of sexual discrimination. She also presented some genuine factual disputes suggesting the reasons for dismissal in the termination letter were pretextual. Cullinan had, on several occasions, complained about Lewis's appearance and made several unsuccessful efforts to remove her from the front desk. Besides, the district court had made an error by burdening her responsibility of demonstrating she had been treated differently from men. Taking these factual and legal bases into consideration, the Eight Circuit overturned the previous ruling, thus allowing the parties to pursue further judicial proceedings. Although the Cullinan had argued that Lewis was terminated because she was against the policies of the company, her claim is baseless. All evidence point that Cullinan violated Title VII when discharging Lewis.

Reference

Bryant v. Aiken Reg'l Med. Ctrs. Inc., 333 F.3d 536, 545 (4th Cir.2003).

Connecticut v. Teal, 457 U.S. 440, 453-54, 102 S.Ct. 2525, 73 L.Ed.2d 130 (1982)

Griffith v. City of Des Moines, 387 F.3d 733, 736 (8th Cir.2004)

Lewis v. Heartland Inns of Am., L.L.C., 585 F.Supp.2d 1046, 1059 (8th Cir.2010)