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STATE OF MINNESOTA IN COURT OF APPEALS A10-1036 John O. Coursolle, Appellant, vs. EMC Insurance Group, Inc., an Iowa corporation, et al., Respondents. Filed February 8, 2011 Affirmed Johnson, Chief Judge Hennepin County District Court File No. 27-CV-09-11702

Philip G. Villaume, Jeffrey D. Schiek, Villaume & Schiek, P.A., Bloomington, Minnesota (for appellant) V. John Ella, Sara Sidwell, Jackson Lewis LLP, Minneapolis, Minnesota (for respondents)

Considered and decided by Johnson, Chief Judge; Klaphake, Judge; and Harten, Judge.* SYLLABUS Constructive discharge is not an independent cause of action. Constructive discharge is a doctrine that may be invoked by a plaintiff in some employment-related actions to prove that the defendant made an adverse employment action.

Retired judge of the Minnesota Court of Appeals, serving by appointment pursuant to Minn. Const. art. VI,

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