Cited by

(remanding for further findings because the district court did not identify its method of analysis and otherwise failed to make findings which hampered “effective appellate review”).

Although Minnesota courts applying the MHRA in the employment-discrimination context often look to federal Title VII caselaw for “guidance,” we are not bound by federal decisions, Hinckley Square Assocs.

A plaintiff may prove a reprisal claim by direct evidence or by “using circumstantial evidence in accordance with the three-part [McDonnell Douglas] burden-shifting test.” Hoover, d at 542; - 40 (Minn. App. 2009) (explaining direct method of proof).

This test first “requires a plaintiff to establish a prima facie case of 8 discrimination.”

The purpose of this framework is “to disprove the most obvious legitimate bases for the employment decision, thereby allowing the inference that the decision was motivated by discrimination.” Friend v. Gopher Co.

See Desert Palace, Inc. v. Costa, 539 U.S. 90, 99 -100 (2003); Hoover, d at 542; Friend v. Gopher Co.

McDonnell Douglas, 411 U.S. at 802 n.13; (stating that the purpose of a prima facie showing “is to disprove the most obvious legitimate bases for the employme nt decision”).

McDonnell Douglas, 411 U.S. at 802 n.13 , 93 S. Ct. at 1824 n.13; see also Swierkiewicz v. Sorema N. A., 534 U.S. 506, 512, 122 S. Ct. 992 , 997 -98 (2002) ( observing that t he required prima facie operates as a “flexible evidentiary standard” that was “never intended to be rigid, 14 mechanized, or ritualistic”); (noting that the prima facie case “varies depending on the type of employment decision” and explaining that the purpose of the prima facie case is “to disprove the most obvious legitim

7 “A plaintiff proceeding under a direct -evidence framework need not establish a McDonnell Douglas prima facie case.”

Banking, see also Friend v. Gopher Co. , -40 (Minn. App. 2009) (explaining th e direct method of proof ).

See Boldt v. N. States Power Co., 904 F.3d 586, 591 (8th Cir. 2018); Friend v. Gopher Co., Inc.

“In an appeal from judgment following a court trial, we defer to the district court’s findings of fact unless clearly erroneous.” Friend v. Gopher Co., Inc.

7(d) (authorizing this court to remand for further proceedings); Friend v. Gopher Co. , (“[W]e conclude that the findings are insufficient to permit effective appellate review and we remand for the district court to make further findings.”) .

See Friend v. Gopher Co. , (“[W]e conclude that the findings are insufficient to permit effe ctive appellate review and we remand for the district court to make further findings.”).1 Second, there are no written materials in the record that contradicted the misinformation Sangwan testified she received.

-24 (Minn. 2001); Friend v. Gopher Co., Inc.

“In contrast to the process of elimination that takes place under McDonnell Douglas, direct- evidence cases are adjudicated based on the strength of affirmative evidence of discriminatory motive.”

-24 (Minn. 2001); review denied (Minn. Nov.

Cases decided under the direct-evidence framework for proving a disparate- treatment claim are “adjudicated based on the strength of affirmative evidence of discriminatory motive.”

1 In doing so, a plaintiff may rely on both direct and circumstantial evidence.

See Friend v. Gopher Co., Inc., (“Minnesota law makes no distinction between circumstantial and direct evidence as to the degree of proof required.” (quotation omitted)).

(“Because the district court’s findings are insufficient to permit reasoned appellate review, we reverse and remand for further findings.”).