Understanding the Court System
Student’s Name
Instructor’s Name
Course Title
April 20, 2020
Understanding the Court System
Brenna Lewis v. Heartland Inns of America, L.L.C.
Seminal Facts About the Case
The court case used in this study was a lawsuit between Brenna Lewis and Heartland Inns of America, L.L.C. Brenna Lewis, the plaintiff, had sued Heartland Inns, a business entity, over claims of sexual discrimination in an employment dispute. Other parties to the case were Barbara Cullinan, and Kristi Nosbisch, employees of Heartland, who were sued in both their individual and corporate capacities (Bye et al., 2010). The case was an appeal, lodged at the United States Court of Appeals for the eighth circuit, from the United States District Court, the Southern District of Iowa. The appeal was registered on October 21, 2009, and filed on January 21, 2010. It was listened by Loken, as the chief judge, and Murphy and Bye, as the circuit judges.
The contentious issues resulting in the lawsuit were claims of sexual discrimination by Brenna Lewis against her former employer, Heartland Inns of America. According to Lewis, Heartland had sacked her based on her sexual orientation. Therefore, she was suing her former employer against sex-based discrimination (Bye et al., 2010). Lewis worked in the organization for more than a year and a half before the contentious issues arose. She joined the firm in 2005, as a night shift auditor, where she worked at the organization’s Waterloo Crossroads branch. She also worked as a front desk officer in the same facility from 11:00 p.m. to 7:00 a.m. At the facility, her manager rated her as a top performer and even requested a pay rise for her (Bye et al., 2010). Lewis had also received a positive compliment from a client due to her excellent service.
In December 2007, Lewis began working at Heartland Inns’ branches, Ankeny and Altoona, near Des Moines. At Altoona, the manager Jennifer Headington found Lewis a performer and requested Cullinan’s permission, the firm’s Director of operations, to hire Lewis as a full-time auditor for the night shift (Bye et al., 2010). Shortly, Lewis manager at Ankeny offered Lewis a full-time position at the front desk, during the A shift due to her excellent performance. Cullinan had never seen Lewis, and she only authorized Headington and Stifel to hire her through the phone.
Lewis’ issues at Heartland began when Cullinan found her working at the front desk in Ankeny. Cullinan’s concern was that Lewis’ lacked the “Midwestern girl look,” and she appeared more muscular. According to her, a person working at the front desk had to be more feminine and appealing. Though Lewi’s performance at the position exceeded expectations, Cullinan was concerned Lewis was not pretty enough (Bye et al., 2010). Cullinan informed Stifel that the firm had regressed two steps back by hiring Lewis. She demanded Lewis be subjected to a second interview, which Lewis objected, referring it as discriminatory since other staff in similar conditions had not undergone the same. She said it was meant to deny her the opportunity. She was accused of insubordination and fired three days later after objecting to the interview (Bye et al., 2010). She filed a suit at the Iowa District Court, where the case received summary judgment and with a remand order.
The primary Laws Violated on Lewis v. Heartland Inns’ Case
The central claims by Lewis against her employer Heartland Inns were sexual discrimination and retaliation. From the evidence and testimonials made in the case, it is evident that Heartland Inns, and agents acting on its behalf, violated various laws and regulations in dismissing Lewis due to her sexual orientation.
Lewis’ dismissal from her position at the front desk had nothing to do with her performance or any disciplinary case. It was purely on Cullinan’s dislike of her physical appearance, which was considered more masculine and lacking the ‘Midwestern girl look.” In dismissing Lewis, Heartland Inns and its agents violated Title VII of the Civil Rights Act of 1964, on unlawful employment practices, SEC.2000e-2.[Section 703], which states that ” It shall be an unlawful employment practice for an employer to fail or refuse to hire or discharge any individual, or otherwise to discriminate against any individual concerning his compensation, terms, conditions, or privileges of employment, because of such individual’s race, color, religion, sex, or national origin.” Therefore, Heartland’s decision to sack Lewis from her position due to failure to comply with certain sexual stereotypes was in contravention to the above clause, which outlaws any form of employment discrimination based on sexual orientation.
Besides, Heartland’s decision to dismiss Lewis from her position due to lack of a “feminine look” violated the Iowa Civil Rights Act of 1965 (ICRA), Iowa Code 216.6, on unfair employment practices. The Act outlaws any form of discrimination against employees by employers based on sex or sexual orientation. Heartland’s Act of firing Lewis due to her failure to meet their expectations on physical appearance violated this clause. The organization’s expectations were informal since no formal guidelines governed the physical appearance of female workers in the firm. Also, the company went against the ICRA of 1965, code 216.11, which declared retaliation as discriminatory. The firm retaliated against Lewis’ refusal to participate in the unfair interview.
Possible Penalties for Unfair Employment Practices
If a court of law finds an employer or an organization guilty of employment discrimination based on sex like in the case of Lewis and Heartland Inns, the court can order the following measures: reinstatement of the employee to the previous position in case such employee was dismissed on unfair grounds. In case of discrimination in the hiring process, the court can order the employer to hire the aggrieved party. The court can also award damages and compensation to the individual directly affected by the discrimination according to the Civil Rights Act, Title 42 of U.S. Code. In this case, Lewis qualifies for damages. Besides, an employer found guilty of violating Title VII can be ordered to pay penalties and injunctive relief. The damages can include back pay, out of pocket costs, front pay, court expenses, and attorney fees. Also, in some cases, the victim can be awarded compensatory damages for emotional suffering occasioned by the discrimination. The employer can also be charged for punitive damages, aimed at punishing such an employer for the Act of discrimination. Additionally, the employer is ordered to post in conspicuous places, notices that speak against discrimination as directed by the court or the Equal Employment Opportunity Commission.
Jurisdictional Requirements: Why the Case was Heard in the Appellate Court
Initially, the case of Brenna Lewis v. Heartland Inns was lodged at a state court, the District Court for the Southern District of Iowa. The court had the jurisdictional authority to hear and determine the case since it occurred within its area of jurisdiction. The district court granted summary judgment to Heartland. However, the plaintiff, Brenna Lewis, was unsatisfied with the ruling and chose to appeal (Bye et al., 2010). That is how the case got to the United States Court of Appeals for the eighth circuit. The court of appeal for the eighth circuit had the jurisdiction to hear the suit since the district court falls within its circuit.
The outcome of the Case
The Appellate court, for the eighth circuit, in a ruling filed on January 21, 2010, for the case number 08-3860, overturned the decision of the District Court for the Southern District of Iowa, which had granted summary judgment to Heartland on the case pitting Brenna Lewis against Heartland Inns (Bye et al., 2010). The case was heard by a bench of three judges, Loken, the chief judge, Murphy, and Bye, circuit judges. In a majority ruling, Murphy and Bye found the district court to have erred in its summary judgment while Loken, the chief judge, dissented and upheld the decision of the lower court (Bye et al., 2010). The court found Heartland guilty of a violation of Title VII of the human rights act as well as state laws against discrimination. The judges found that Heartland’s argument for firing Lewis was pretextual since Lewis had a record of satisfactory performance and no disciplinary history. Heartland was also found guilty of retaliating against Lewis for her refusal to participate in the discriminating second interview. In a dissenting opinion, judge Loken stated that an employer’s decision to hire or fire an employee due to such an employee’s physical appearance is not discrimination (Bye et al., 2010). He upheld the decision of the district court.
Whether the Outcome of the Case was Justified
In my view, I believe the appellate court’s decision to find Heartland guilty of discrimination was justified. Any fact finder would find a causal nexus between Lewi’s physical appearance, the comments of her supervisor Cullinan, and her dismissal. Since Lewis had a record of excellent performance and no disciplinary history, it is only logical to conclude that her termination was purely due to her physical appearance, which lacked the “Midwestern girl look.” Therefore, the court of appeal was right in finding Heartland Inns guilty of sexual discrimination since it outrightly violated Title VII of the human rights act.
References
“Title VII of the Civil Rights Act of 1964.” (1964). United States Code. Department of Justice. https://www.justice.gov/sites/default/files/crt/legacy/2010/12/15/Title_VII_Statute.pdf
Civil Rights: Title 42 U.S. Code Subchapter VI on Equal Employment Opportunities. (n.d). Legal Information Institute. https://www.law.cornell.edu/uscode/text/42/chapter-21/subchapter-VI
Iowa Civil Rights Act, Iowa Code Chapter 216. (n.d). Civil Rights Commission. https://www.legis.iowa.gov/DOCS/ACO/IC/LINC/Chapter.216.pdf
Loken, J., Murphy, D. Bye, K. (2010). Appellate Case 08-3860-Brenna Lewis v. Heartland Inns of America, et al. U.S. Government Publishing Office. https://www.govinfo.gov/content/pkg/USCOURTS-ca8-08-03860/pdf/USCOURTS-ca8-08-03860-0.pdf