Murray v. Mayo Clinic
United States Court of Appeals for the Ninth Circuit
June 13, 2019, Argued and Submitted, San Francisco, California; August 20, 2019, Filed
[*1102] PEARSON, District Judge:
Plaintiff Michael Murray appeals the district court's instruction to the jury on his claim under the Americans with Disabilities Act ("ADA"), requiring him to prove that he was discharged because of his disability. Murray claims that our decision in Head v. Glacier Northwest, Inc., 413 F.3d 1053 (9th Cir. 2005), holding ADA discrimination claims are evaluated under a motivating factor causation standard, remains good law. Because it is not, we affirm.
Dr. Murray filed suit against Mayo Clinic, Mayo Clinic Arizona, Drs. Wyatt Decker, Lois Krahn, Terrence Trentman, William Stone, and David Rosenfeld, and Operations Administrator Roshanak Didehban. In anticipation of trial, the parties submitted joint proposed jury instructions. The parties disagreed whether Murray's ADA discrimination claim should be tried under a but-for causation standard or a motivating factor causation standard. Murray argued that our decision in Head required him to show only that the defendants' belief that he had [**3] a disability was a motivating factor in their adverse employment decision. He accordingly requested the following instruction:
As to Dr. Murray's claim that his disability was the reason for Mayo Clinic Arizona's decision to discharge him, Dr. Murray has the burden of proving the following evidence by a preponderance of the evidence:
. . .
3. Dr. Murray was discharged because Defendants regarded him as disabled, which means that Defendants' belief that [*1103] Plaintiff had a disability was a motivating factor in Defendants' decision to terminate him.
The district court instead instructed the jury to apply a but-for causation standard to Murray's ADA claim. The instruction provided that Murray must prove he was discharged because of his disability:
As to Dr. Murray's claim that his disability was the reason for Mayo Clinic Arizona's decision to discharge him, Dr. Murray has the burden of proving the following evidence by a preponderance of the evidence:Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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934 F.3d 1101 *; 2019 U.S. App. LEXIS 24734 **; 2019 WL 3926945
MICHAEL J. MURRAY, M.D. - a married man, Plaintiff-Appellant, v. MAYO CLINIC, a Minnesota nonprofit corporation; MAYO CLINIC ARIZONA, an Arizona nonprofit corporation; WYATT DECKER, M.D. - husband; GEORGIANNA DECKER, wife; LOIS KRAHN, M.D. - wife; ERIC GORDON, M.D. - husband; TERRENCE TRENTMAN, M.D. - husband; LARALEE TRENTMAN, wife; WILLIAM STONE, M.D. - husband; MAREE STONE, wife; DAVID ROSENFELD, M.D. - husband; MELISSA ROSENFELD, M.D. - wife; ROSHANAK DIDEHBAN, a single woman, Defendants-Appellees.
Prior History: [**1] Appeal from the United States District Court for the District of Arizona. D.C. No. 2:14-cv-01314-SPL. Steven Paul Logan, District Judge, Presiding.
Murray v. Mayo Clinic, 2016 U.S. Dist. LEXIS 193062 (D. Ariz., Jan. 11, 2016)
motivating factor, disability, causation, circuits, discrimination claim, but-for, cases, intervening, plain language, irreconcilable, remedies
Civil Procedure, Appeals, Standards of Review, Abuse of Discretion, De Novo Review, Trials, Jury Trials, Jury Instructions, Business & Corporate Compliance, Disability Discrimination, Scope & Definitions, Discriminatory Conduct, Labor & Employment Law, Discrimination, Title VII Discrimination, Scope & Definitions, Governments, Courts, Judicial Precedent, Evidence, Burdens of Proof, Employee Burdens of Proof, Age Discrimination, Burdens of Proof