October 6, 2015

Jack Link’s Missing Link: Company Pays $50K to Settle Claim of Ongoing Sexual Harassment

Posted in Discrimination, Employee Handbooks, Gender / Sex, Harassment, Harassment, Hostile Work Environment, Minnesota Human Rights Act, Sexual Harassment, Sexual Harassment, Title VII of the Civil Rights Act of 1964, Uncategorized tagged , , , , , , , at 10:28 am by Tom Jacobson

A recently settled Minnesota Department of Human Rights charge against Jack Link’s Beef Jerky emphasizes the importance of follow-through when responding to sexual harassment allegations. According to the Department, Jack Link’s initially took the “right step” in disciplining the alleged harasser but then failed to monitor the situation, which included ongoing harassment.

Specifically, MDHR reports that shortly after being hired by Jack Link’s, a female employee’s supervisor made sexual advances toward her, called her “baby,” said she was beautiful, asked if she was single, chanted “pack baby pack,” and asked if he was too old for her. The Department also reports that although Jack Link’s initially disciplined the supervisor, the company then promoted him to be woman’s direct supervisor, after which he continued to harass the employee. Claiming she could no longer tolerate the work environment, the woman quit.

Thus, based on the MDHR’s findings, the missing link in Jack Link’s response was the lack of follow-through and monitoring. As noted by MDHR Commissioner Kevin Lindsey:

This is an unusual case in that the employer took the right step in originally disciplining the supervisor. The employer however undermined its efforts by not subsequently monitoring the actions of the alleged harasser. Employers need to maintain contact with the employee who has complained of sexual harassment to make sure that the measures that they have undertaken are actually working.

To settle the charge, Jack Link’s agreed to pay the victim $50,000.00 and to provide training on the Minnesota Human Rights Act and how to properly respond to sexual harassment allegations.

Generally speaking, employers must first take steps to prevent unlawful workplace harassment. But if, despite those efforts, an employee claims that harassment has occurred, employers must take prompt action to correct and stop that behavior. As the Jack Link’s case points out, this includes careful monitoring and follow-through to make sure the harassment does not continue or recur.

For more information about this article or about the harassment training, policy development, and related services I can provide, please contact me at alexandriamnlaw.com or  taj@alexandriamnlaw.com.

The comments posted in this blog are for general informational purposes only. They are not to be considered as legal advice, and they do not establish an attorney-client relationship. For legal advice regarding your specific situation, please consult your attorney.

Copyright 2015 Swenson Lervick Syverson Trosvig Jacobson Schultz Cass, PA

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October 16, 2014

Workplace bullying: on the job with Scut Farkus

Posted in Bullying, Bullying, Cyber Bullying, Discrimination, Harassment, Harassment, Hostile Work Environment, Workplace Violence tagged , , , , at 10:30 am by Tom Jacobson

Scut Farkus

Scut Farkus – future workplace bully?

In the holiday classic A Christmas Story, playground bully Scut Farkus torments Ralphie Parker until Ralphie pummels Scut after one too many snowballs to the face. We cheer for Ralphie because he’s the good kid who takes a stand against Scut’s relentless bullying. But what happens when Scut gets a job? What is the law on workplace bullying?

I recently attended a community conversation about workplace bullying. The discussion confirmed that there is much confusion about the topic. The debate is no doubt fueled by recent media attention and legislative attempts to regulate bullying.

Those efforts have been partially successful in the school setting. For example, the State of Minnesota earlier this year passed the Safe and Supportive Schools Act. This new law defines and regulates bullying in the state’s public and charter schools. However, workplace bullying is neither defined nor prohibited by any state or federal law.

Even if the conduct creates a hostile work environment, bullying alone is not unlawful unless the behavior violates some other established law. Recent court decisions emphasize how difficult it is to turn garden-variety bullying into a legal claim.

For example, in Johnson v City University of New York, an employee claimed that a co-worker’s bullying violated Title VII. The judge last month threw out the case, saying:

Victims of non-discriminatory bullying at the workplace, like those treated unfairly for reasons other than their membership in a protected class, must look outside Title VII to secure what may be their fair due. The Court does not condone bullying, but it cannot read Title VII to protect its victims unless the bullying reflects discrimination based on race, color, religion, sex, or national origin.

The Minnesota Court of Appeals last year overturned a $270,000.00 Ramsey County jury verdict in favor of an employee who reported being bullied by his boss (see Absey v. Dish Network, LLC). Because Minnesota has no anti-workplace bullying law, the plaintiff’s legal theory was actually based on Minnesota’s whistle-blower law, Minn. Stat. § 181.932. In reversing the jury’s verdict, the Court of Appeals ruled that the plaintiff failed to prove that the employer’s adverse action against him was because he complained about his boss.

Bullied employees have found some limited success in the courts. In one Indiana case, Raess v. Doescher, an employee won a lawsuit based on his employer’s behavior, which the court described as “aggressively and rapidly advanc[ing] on the plaintiff with clenched fists, piercing eyes, beet-red face, popping veins, and screaming and swearing at him.” This conduct could certainly be characterized as “bullying,” but the plaintiff won his case not because he was “bullied” but because the jury found the employer’s conduct to be an assault under Indiana law.

These cases underscore the current reality that when employees are confronted by a Scut Farkus-like co-worker, there are no laws specifically defining or prohibiting workplace bullying. However, if the bully’s conduct is egregious enough, there already exist other legal claims that could provide recourse. In addition to assault and whistle-blower claims, it is conceivable that under the right set of facts, bullied employees could successfully sue for intentional infliction of emotional distress, negligence or other wrongs based on another employee’s bullying behaviors. And, when bullying is based on employees’ protected class status, they may have viable claims under Title VII and/or comparable laws.

But rather than litigation and legislation, perhaps the better solution is to curb such behaviors through better employment policies and practices that encourage and model respectful working relationships.

For more information about this article, please contact me at alexandriamnlaw.com or  taj@alexandriamnlaw.com.

The comments posted in this blog are for general informational purposes only. They are not to be considered as legal advice, and they do not establish an attorney-client relationship. For legal advice regarding your specific situation, please consult your attorney.

Copyright 2014 Swenson Lervick Syverson Trosvig Jacobson Schultz, PA

October 9, 2014

Employment retaliation: the high cost of revenge

Posted in Discrimination, National Origin, Race, Retaliation, Title VII of the Civil Rights Act of 1964 tagged , , , , , , at 7:40 pm by Tom Jacobson

Kinkead 10-10-14

While seeking revenge, dig two graves; one for yourself. Douglas Horton

Most laws granting rights to employees include anti-retaliation provisions intended to protect the employees who exercise those rights. Title VII of the Civil Rights Act of 1964 is no exception. Buffalo, MN based Izza Bending Tube & Wire and Wells Fargo & Co. recently learned that lesson the expensive way. That is, via costly settlements of EEOC employment retaliation charges.

Both cases were investigated by the Minneapolis, MN area office of the EEOC. In the Wells Fargo case, the EEOC determined that an employee reported to the company’s human resources department that she was being subjected to differential treatment based on her race and national origin. The agency also found that the employee’s supervisor told her not to speak Spanish during her non-duty time. Shortly after the employee’s report, the EEOC found, Wells Fargo disciplined and then terminated the employee for practices other employees regularly engaged in without discipline. This, the EEOC concluded, violated the employment retaliation provisions of Title VII.

To resolve the charge, Wells Fargo agreed to pay $295,000.00. The company also agreed to:

  • Conduct training on the laws prohibiting employment discrimination, with special emphasis on employment retaliation and English-only speaking requirements;
  • Distribute to all employees an annual e-mail affirming its commitment to diversity, multilingual ability and the use of languages other than English in the workplace;
  • Report to the EEOC all allegations of discrimination or employment retaliation annually for three years.

In the Izza case, the EEOC alleged that a manager first instructed an employee to not hire a black temporary worker for a permanent position and then told the employee to get rid of him because of his race. The EEOC further alleged that after the employee filed a discrimination charge with the EEOC, she was laid off and then terminated in retaliation. Izza settled the case by paying $45,000.00 and agreeing to train employees and report any retaliation complaints to the EEOC.

The main takeaway from these cases is that retaliating against employees who exercise their Title VII rights is by itself a violation of Title VII, and resolving those cases can be extremely expensive. The same holds true for employees who exercise their rights under the Minnesota Human Rights Act and many other employment laws. Moreover, preserving access to the justice system by fighting employment retaliation under Title VII is one of the EEOC’s 2013-2016 Strategic Enforcement Plan priorities. Therefore, employers would be wise to make prohibiting employment retaliation one of their HR priorities. Or, start digging.

For more information about this article, please contact me at alexandriamnlaw.com or  taj@alexandriamnlaw.com.

The comments posted in this blog are for general informational purposes only. They are not to be considered as legal advice, and they do not establish an attorney-client relationship. For legal advice regarding your specific situation, please consult your attorney.

Copyright 2014 Swenson Lervick Syverson Trosvig Jacobson Schultz, PA

May 9, 2014

Legislative update: MHRA jury trials and Women’s Economic Security Act advance

Posted in Care of Relatives Leave, Court Trial, Discrimination, Domestic violence, Family and Medical Leave Act, Family and Medical Leave Act (FMLA), Family Leave, Jury Trial, Leaves of Absence, Nursing Mothers, Parenting Leave, Remedies, Sick Leave, Sick or Injured Child Care Leave tagged , , , , , , , , , , at 9:26 am by Tom Jacobson

Both houses of the Minnesota Legislature on May 8, 2014 took action to advance legislation which, if signed into law by Gov. Mark Dayton, will have significant impacts on Minnesota employers and employees.

First, with a 43-24 vote the Senate approved the Women’s Economic Security Act (HF2536) which, among other things, would expand parenting and sick leave rights. For more information on this bill, see Women’s Economic Security Act Passed by MN House.

Then, with a 79-51 vote the House approved the Senate’s amendment to the Minnesota Human Rights Act (MHRA) (SF 2322). This amendment would add the right to a jury trial as a remedy under the MHRA. For more information on this bill, see Minnesota Senate Adds Jury Trial Right to Minnesota Human Rights Act.

For more information about this legislation, please contact me at taj@alexandriamnlaw.com.

The comments posted in this blog are for general informational purposes only. They are not to be considered as legal advice, and they do not establish an attorney-client relationship. For legal advice regarding your specific situation, please consult your attorney.

Copyright 2014 Swenson Lervick Syverson Trosvig Jacobson Schultz, PA

May 6, 2014

MN Senate adds jury trial right to Human Rights Act

Posted in Court Trial, Discrimination, Jury Trial, Remedies tagged , , , , , , at 9:14 am by Tom Jacobson

SF 2322By changing a single sentence in the Minnesota Human Rights Act (MHRA), the Minnesota Senate on May 1, 2014 passed a bill which, if it becomes law, will significantly change the way MHRA disputes are decided in the courtroom.

Currently, the law (Minn. Stat. § 362A.33, subd. 6) provides that, “Any action brought pursuant to this chapter shall be heard and determined by a judge sitting without a jury.” However, the Senate’s version (SF 2322), which passed on a 55-0 vote, would change that sentence to read, “A person bringing a civil action seeking redress for an unfair discriminatory practice or a respondent is entitled to a jury trial.”

The change would be significant, for it would drastically change the way MDHR cases — such as claims for employment discrimination — would be litigated. Generally speaking, jury trials are far more expensive and complicated than are cases tried to a judge alone. A jury of six people can also be far more difficult to predict than a single judge. The change would, however, make state law consistent with its federal counterpart (Title VII of the Civil Rights Act of 1964), which already allows for jury trials.

For more information about this article, please contact me at alexandriamnlaw.com or  taj@alexandriamnlaw.com.

The comments posted in this blog are for general informational purposes only. They are not to be considered as legal advice, and they do not establish an attorney-client relationship. For legal advice regarding your specific situation, please consult your attorney.

Copyright 2014 Swenson Lervick Syverson Trosvig Jacobson Schultz, PA

June 13, 2013

Marital status protection trumps conflict policy, says MN Court of Appeals

Posted in Discrimination, Legitimate Business Reason for Termination or other Adverse Action, Marital Status tagged , , , , , , , , at 9:52 am by Tom Jacobson

Wedding Casual

Newlyweds, Camden State Park (August 6, 1988)

Twenty-five years ago this summer, my wife and I were married in the most beautiful outdoor ceremony at Camden State Park.  We had both worked there for several summers — she in the park office and I on the beach. We’ve never worked for the same employer since, though I’m sure we’d make a great team if we did. And, if things didn’t work out with our mutual employer such that one of us wanted to quit and go to work for a competitor, the Minnesota Court of Appeals has granted some protection to the one who stays.

The protection was granted in the case of Aase v. Wapiti Meadows Community Technologies and Services, Inc., which involved a situation where a husband and wife (April and Mark Aase) both worked for Wapiti Meadows, d/b/a Community Technologies and Services (CTS). Mr. Aase resigned and accepted a position with a competitor of CTS. CTS then fired Mrs. Aase and claimed that it did so because Mrs. Aase failed to cooperate with the company’s efforts to mitigate the potential conflict of interest. However, other evidence suggested that CTS fired Mrs. Aase because of her husband’s work for the competitor.

Mrs. Aase sued, claiming her termination violated the marital status discrimination provisions of the Minnesota Human Rights Act (MHRA), which makes it an unfair employment practice for an employer to discharge an employee because of marital status. This includes protection against discrimination on the basis of identity, situation, actions, or beliefs of a spouse or former spouse. The trial court dismissed the case based in part on its conclusion that it was legitimate and non-discriminatory for the company to fire Mrs. Aase because she would violate the company’s conflict of interest policy if her husband worked for the competitor.

Mrs. Aase appealed that decision to the Court of Appeals, which then had to decide whether the conflict of interest was a legitimate reason for firing Mrs. Aase. The court said no, “It was not a legitimate, nondiscriminatory act for CTS to discharge Aase solely based on the actions of her husband, even if CTS believed those actions violated the conflict-of-interest policy.” The appellate court then remanded the case for a trial where the trial court will need to decide whether CTS fired Mrs. Aase due to the conflict of interest involving her husband or for some other legitimate non-discriminatory reason.

What you need to know: Minnesota law prohibits employers from discriminating against employees due to their marital status. This includes the identity, situation, actions and beliefs of a spouse. Employers may, however discharge employees for legitimate non-discriminatory reasons. Based on the Wapiti Meadows case, the conflict that may exist when an employee’s spouse works for a competitor is not a legitimate non-discriminatory reason for discharging an employee.

For more information about this article, please contact me at alexandriamnlaw.com or  taj@alexandriamnlaw.com.

The comments posted in this blog are for general informational purposes only. They are not to be considered as legal advice, and they do not establish an attorney-client relationship. For legal advice regarding your specific situation, please consult your attorney.

Copyright 2013 Swenson Lervick Syverson Trosvig Jacobson Schultz, PA

January 4, 2013

Swine flu as ADA disability? Maybe when pigs fly …

Posted in Americans with Disabilities Act, Disability, Discrimination, Regarded as Disabled tagged , , , , , , , , at 4:58 pm by Tom Jacobson

Dec. 26, 2012 -- Under the London Bridge, Lake Havasu, AZ

Dec. 26, 2012 — Under the London Bridge, Lake Havasu, AZ

Over Christmas I joined my wife’s family for an escape to Lake Havasu, AZ. We enjoyed the warm sun, visited the re-constructed London Bridge, lounged by the pool, and even though many of the 17 of us shared a cold, we had a fantastic time. And when it was time to get back to the office, no one fired me over a fear that I might infect everyone with some contagious disease I may have picked up while out-of-state.

Francisco Valdez was not so lucky.  According to court documents, Valdez worked for Minnesota Quarries, Inc. d/b/a Mankato Kasota Stone, Inc. In the spring of 2009 Valdez traveled to his native Mexico to visit his gravely ill sister who died while he was en route. At the time, the Centers for Disease control had advised against non-essential travel to Mexico due to a swine flu outbreak there. When Valdez tried to return to work a week later, the company’s HR director told him that he was being terminated because the company feared he might have contracted swine flu and because he had violated the company’s no-call/no-show policy.

Valdez sued Kasota Stone, alleging among other things that being fired because of a fear that he had swine flu violated the Americans with Disabilities Act. Specifically, Valdez claimed that because Kasota Stone was afraid he had swine flu, the company regarded him as disabled. Under the ADA, the term “disability” includes being “regarded as” having an impairment that substantially limits one or more of a person’s major life activities; therefore, the ADA makes it unlawful for an employer to discriminate against employees who it regards as having such impairments.

In a December 10, 2012 decision Judge Patrick J. Schiltz of the United States District Court for the District of Minnesota rejected Valdez’s claims. The court first noted that in “regarded as” cases under the ADA, “An employee is not ‘regarded as’ disabled if the impairment that he is regarded as having is both ‘transitory and minor.'” The court also pointed out that federal regulations exclude “common ailments like the cold or flu” from being considered as disabilities in “regarded as” cases. The court then concluded that despite the subjective fear of swine flu, the objective medical evidence indicates that in reality, swine flu is no more severe than “seasonal flu.” Thus, the court dismissed Valdez’s case after ruling that, “Because swine flu is objectively transitory and minor, it is not a disability under the “regarded as” prong of the ADA…. Valdez therefore cannot be considered disabled within the meaning of the ADA.”

What you need to know: Discriminating against an employee because he or she is “regarded as” having a disability is as unlawful as discriminating against one who actually has a disability. Although the Valdez case emphasizes that not every feared ailment is protected by the ADA, employers must exercise extreme caution if they want to take action against an employee because of his or her actual or perceived state of health.

For more information about this article, please contact me at taj@alexandriamnlaw.com.

The comments posted in this blog are for general informational purposes only. They are not to be considered as legal advice, and they do not establish an attorney-client relationship. For legal advice regarding your specific situation, please consult your attorney.

Copyright 2013 Swenson Lervick Syverson Trosvig Jacobson Schultz, PA

May 17, 2012

Sex-based Hostile Work Environment Claims Clarified by MN Supreme Court

Posted in Discrimination, Gender / Sex, Harassment, Hostile Work Environment, Sexual Harassment tagged , , , , , , at 11:58 am by Tom Jacobson

The term “hostile work environment” is one of the most commonly misunderstood terms in the world of employment law. For example, I’ve heard many employees complain that they work in a hostile environment because their boss is a jerk or because their co-workers are mean to them. While such an environment may indeed be hostile, hostility is generally not a sufficient basis for a legal challenge unless it is based on a person’s protected classification, such as his or her sex.

But even when it comes to sex-based hostile work environment claims, there has been a lingering question: If a person is targeted with hostility because of his/her sex, but the hostility is not sexual in nature (for example, unwelcome sexual advances, requests for sexual favors, sexually motivated physical contact or other verbal or physical conduct or communication of a sexual nature), may the sex-based hostility be the basis of a hostile work environment claim under the Minnesota Human Rights Act (MHRA)?  The Minnesota Supreme Court has now answered that question in the affirmative.

In the case of LaMont v. Independent School District #728, which the Court decided on May 16, 2012 Carol LaMont was employed as a custodian by Independent School District #728 in Elk River, MN. LaMont was supervised by a male, Doug Miner, who she claimed made frequent comments about his negative view of women in the workplace. LaMont also claimed that Miner treated men and women differently regarding certain terms and conditions of employment. She did not allege that Miner’s conduct was sexual in nature.  Relying on the MHRA, LaMont sued the school district based on a hostile work environment sex discrimination theory.

As a threshold issue, the Court had to decide whether a hostile work environment claim under the MHRA can be based on harassing conduct that is based on sex, even if the offending conduct is not sexual. To reach its decision, the Court first noted that the MHRA’s definition of discrimination “does not limit claims of a hostile work environment to sexual harassment.”  The Court then noted how in prior cases, it had recognized that “sexual harassment is just one form of  hostile work environment that constitutes sex discrimination in the terms and conditions of employment.” Finally, the Court found support from federal cases interpreting Title VII of the Civil Rights Act of 1964. Ultimately, the Court said:

For the foregoing reasons, we conclude that the MHRA permits a hostile work  environment claim based on sex. We hold that verbal and physical harassment directed at an employee because of her sex may constitute discrimination in the terms and conditions of employment.

Turning then to the specific allegations in the LaMont case, the Court found that even though these types of claims can be brought under the MHRA, Lamont’s allegations were not enough to support a claim under the law.

What you need to know:  Even though Lamont ultimately lost, the Minnesota Supreme Court ruled in her case that a hostile work environment claim under the MHRA can be based on harassing conduct that is based on sex, even if the offending conduct is not sexual. This makes it even more important for employers to adopt and enforce policies which prohibit sex discrimination.

For more information about this article, please contact me at taj@alexandriamnlaw.com.

The comments posted in this blog are for general informational purposes only. They are not to be considered as legal advice, and they do not establish an attorney-client relationship. For legal advice regarding your specific situation, please consult your attorney.

Copyright 2012 Swenson Lervick Syverson Trosvig Jacobson Schultz, PA

November 2, 2011

Raising Cain: HR lessons from the political battlefield

Posted in Discrimination, Employee Handbooks, Gender / Sex, Sexual Harassment, Sexual Harassment tagged , , , at 10:22 am by Tom Jacobson

Allegations that presidential hopeful Herman Cain sexually harassed employees while he was head of the National Restaurant Association in the 1990’s have sent his campaign into damage control mode (see Herman Cain denies allegations of sexual harassment, Cain says he was “falsely accused” of harassment, Herman Cain reacts to allegations, etc.).  How these allegations will ultimately impact his bid for the White House remains to be seen, but the story gives us a chance to reflect again on the overall problem of sexual harassment.

Sexual harassment has been recognized as a form of unlawful sex discrimination since the 1980’s, but it continues to be a problem in the workplace.  The Equal Employment Opportunity Commission reports that in 2010 there were 11,717 charges of sexual harassment filed nationwide.  According to the EEOC’s statistics, these charges resulted in $48.4 million in benefits paid, excluding money recovered in litigation.  Of  course, this also does not account for the tremendous expense and disruption that results from investigating and resolving these charges, nor does it account for the countless complaints that are undoubtedly raised and resolved internally by employers each year.

The first step in combating the problem is gaining an understanding of what sexual harassment is.  In Minnesota, the state legislature has defined sexual harassment in the workplace to include:

 …unwelcome sexual advances, requests for sexual favors, sexually motivated physical contact or other verbal or physical conduct or communication of a sexual nature when:

(1) submission to that conduct or communication is made a term or condition, either explicitly or implicitly, of obtaining employment …;

(2) submission to or rejection of that conduct or communication by an individual is used as a factor in decisions affecting that individual’s employment …; or

(3) that conduct or communication has the purpose or effect of substantially interfering with an individual’s employment…, or creating an intimidating, hostile, or offensive employment … environment.

The federal definition is similar, but knowing the definition is only part of the solution.  The definition should also be incorporated into written policies which, among other things, should expressly prohibit sexual harassment, outline what a victim should do if it occurs, and stress that no employee will be retaliated against for raising the issue.  Complaints need to be taken seriously, investigated properly, and resolved promptly and in a way that is likely to end the harassment. Education and training are also key components to preventing sexual harassment.

For more information about sexual harassment policies, investigations or anything else covered in this article, please contact me at taj@alexandriamnlaw.com.

The comments posted in this blog are for general informational purposes only. They are not to be considered as legal advice, and they do not establish an attorney-client relationship. For legal advice regarding your specific situation, please consult your attorney.

Copyright 2011 Swenson Lervick Syverson Trosvig Jacobson Schultz, PA

October 26, 2011

MDHR reports 20% jump in discrimination charges

Posted in Disability, Discrimination, Employee Handbooks, Gender / Sex, Race, Sexual Harassment tagged , , , , , at 12:02 pm by Tom Jacobson

The Minnesota Department of Human Rights reports that during the first half of 2011, it received 455 charges of discrimination.  This represents a twenty percent increase when compared with the previous six month period.

Other notable figures from the MDHR’s report, which was submitted on October 11 to the Minnesota Legislature, include:

  • Disability discrimination charges accounted for the highest percentage of cases (24%); race and sex discrimination were next (15% each).
  • MDHR recovered $209,197 in monetary damages for charging parties.
  • 41 cases were submitted to mediation, and 21 of those cases were settled in mediation.
  • 60% of charges were dismissed for lack of merit.
  • 9% of charges were closed after findings of probable cause, while 16% were closed after findings of no probable cause.
The MDHR is responsible for enforcing the Minnesota Human Rights Act, which covers discrimination in employment, housing, public accommodation and other areas.  However, the vast majority of the MDHR’s activity (61.2%, according to this report), is in the area of employer discrimination.

It is difficult to determine whether the recent surge in charges is due to more aggressive enforcement by the MDHR, better outreach, more unlawful discrimination, and/or greater awareness on the part of employees and other aggrieved parties. Regardless of the cause, the MDHR’s report confirms the importance of maintaining sound equal employment opportunity policies.

For more information about this article, please contact me at taj@alexandriamnlaw.com.

The comments posted in this blog are for general informational purposes only. They are not to be considered as legal advice, and they do not establish an attorney-client relationship. For legal advice regarding your specific situation, please consult your attorney.

Copyright 2011 Swenson Lervick Syverson Trosvig Jacobson Schultz, PA

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