Holbrook v. Minnesota Museum of Art

In 1981, the Minnesota Museum of Art (museum) (defendant) hired Mary Holbrook (plaintiff) as a curatorial assistant. Holbrook held a bachelor of arts degree and had finished the coursework for a master’s degree in classics. Holbrook initially worked 15 hours per week and performed primarily clerical work, although the museum had told her that research would be an important part of the job. In 1983, Holbrook complained about her duties to her supervisor and asked for additional responsibilities. Later, Holbrook was promoted to the position of assistant curator, and Holbrook’s hours increased to 27 and one-half hours per week. By 1985, Holbrook spent most of her time on research and documentation. Approximately one-third of Holbrook’s time was still spent on clerical work, but the curatorial department had no support staff, and even the head curator performed some clerical duties. In 1985, funding limitations led to the elimination of Holbrook’s position. Holbrook was notified that she would be reassigned to two clerical half-time positions, for a total of 40 hours per week, at the same hourly wage she earned as an assistant curator. Holbrook would also receive more benefits working 40 hours per week, and she was told that a review would be held three months later, at which time her role might be upgraded. However, the standard pay scales for the clerical positions were lower than those for Holbrook’s assistant-curator position. Holbrook refused to accept the reassignment and left the museum when the assistant-curator position ended. Holbrook’s application for unemployment-compensation benefits was denied, and the commissioner agreed that Holbrook voluntarily quit. Holbrook appealed.