Lewis v. Heartland Inns of America, Inc.

591 F.3d 1033 (2010)

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Lewis v. Heartland Inns of America, Inc.

United States Court of Appeals for the Eighth Circuit
591 F.3d 1033 (2010)

Facts

Heartland Inns of America, Inc. (Heartland) (defendant) operated hotels. In July 2005, Brenna Lewis began working for a Heartland hotel as a nighttime front-desk worker. Lewis’s supervisor praised her, and Lewis received two merit-based pay raises. In December 2006, Lewis was working front-desk shifts at two Heartland hotels. Supervisors at both locations praised Lewis. They sought and received telephone permission from Barbara Cullinan (defendant), Heartland’s director of operations, to offer Lewis full-time positions. Lewis accepted a day-shift position from manager Lori Stifel. Shortly thereafter, Cullinan visited the hotel. Cullinan told Stifel that Lewis was not a good fit because Lewis lacked a stereotypical feminine appearance, specifically a Midwestern-girl look. Heartland’s personnel manual said nothing about appearance, but Cullinan advocated for pretty employees. Lewis had a slightly masculine figure, short hair, and no makeup and wore men’s button-down shirts and slacks. Cullinan ordered Stifel to move Lewis to the night shift. When Stifel refused, Cullinan forced her to resign. Cullinan then announced a new policy requiring front-desk hires to complete a second interview. Cullinan met with Lewis for a second interview on January 23. Lewis, who had been in her new role for a month, objected, noting that other existing employees were not being interviewed. She expressed belief that the interview resulted from Cullinan’s disapproval of her appearance. Three days later, Lewis was fired. She sued Heartland and Cullinan, alleging sex discrimination violating Title VII of the Civil Rights Act of 1964 (Title VII). Heartland and Cullinan moved for summary judgment, arguing that Lewis’s termination resulted not from discrimination, but from her thwarting the interview procedure and disapproving of Heartland’s new policies. The district court granted summary judgment in Heartland’s and Cullinan’s favor. Lewis appealed.

Rule of Law

Issue

Holding and Reasoning (Murphy, J.)

Dissent (Loken, C.J.)

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