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St. Martin v. City of St. Paul

St. Martin v. City of St. Paul

United States Court of Appeals for the Eighth Circuit

December 14, 2011, Submitted; June 5, 2012, Filed

No. 11-1716

Opinion

 [*1030]  BRIGHT, Circuit Judge.

Scott St. Martin filed suit alleging the City of St. Paul ("the City") engaged in discrimination, on three occasions, by promoting individuals other than him for a fire district chief position in violation of the Americans with Disabilities Act (ADA) and the Minnesota Human Rights Act (MHRA). The district court1 granted summary judgment to the City on all counts. St. Martin now appeals the district court's judgment, contending the district court erred in finding that he is not disabled under the ADA or MHRA, and that he cannot maintain his MHRA claim as to the May 2009 act of alleged discrimination. We affirm.

BACKGROUND

St.  [**2] Martin began working as a firefighter for the City in 1992 and was promoted to captain in 1999. In 2006, he injured his right knee and underwent reconstructive surgery. Consequently, he received workers' compensation from the City. After the surgery, St. Martin returned to work on a light-duty schedule, performing administrative duties at the fire department. Thereafter, he worked briefly as an arson investigator.

In 2007, the City announced an opening for a fire district chief position, which is one rank above captain. St. Martin applied for the position and took a four-part examination. Based on his scores, St. Martin ranked second out of twenty-one candidates. Department chief Timothy Butler then added an interview portion to the exam, and the top five candidates were interviewed by a panel consisting of Butler, three deputy chiefs, and the assistant fire chief of operations. By the time of the interview in February 2008, two additional fire district chief positions had opened up, and as required by the City, St. Martin took a physical exam and received medical clearance from the City's physician. During the interview, Butler asked about St. Martin's knee condition and whether he  [**3] would need accommodations if he was promoted to fire district chief. Despite being the panel's first choice for the position, St. Martin was not promoted; instead, Butler, who had ultimate authority to make the decision, promoted those candidates ranked numbers three, four, and five. According to a union representative for the local fire fighters' union, Butler told her at some point after the interview that he was going to give St. Martin "the disability benefits he wants."

 [*1031]  Another fire district chief position opened up in late 2008. St. Martin applied and interviewed with a panel consisting of Butler, who again inquired about St. Martin's knee issue. Butler then informed St. Martin in a November 2008 email that he would not be promoted. Butler made this decision even though St. Martin was the other panel members' pick. In the email, Butler recommended that St. Martin invest in his professional development, but that "given your medical status that will prove difficult." Butler also sent an email to the City's human resources contact person, stating:

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680 F.3d 1027 *; 2012 U.S. App. LEXIS 11281 **; 26 Am. Disabilities Cas. (BNA) 516; 15 Accom. Disabilities Dec. (CCH) P15-064; 2012 WL 1987874

Scott St. Martin, Plaintiff-Appellant, v. City of St. Paul, Defendant-Appellee.

Subsequent History: Rehearing denied by, Rehearing, en banc, denied by St. Martin v. City of St. Paul, 2012 U.S. App. LEXIS 14862 (8th Cir. Minn., July 19, 2012)

Prior History:  [**1] Appeal from the United States District Court for the District of Minnesota.

St. Martin v. City of St. Paul, 788 F. Supp. 2d 928, 2011 U.S. Dist. LEXIS 22180 (D. Minn., 2011)

CORE TERMS

disability, interview, direct evidence, fire district, impairment, major life activity, summary judgment, candidate, district court, promoted, substantial limitation, broad class, knee injury, openings, accommodate, contends, decision making process, discriminatory animus, ability to work, decisionmaker, landscaping, remarks

Civil Procedure, Summary Judgment, Burdens of Proof, Absence of Essential Element, Appellate Review, Standards of Review, Entitlement as Matter of Law, Appropriateness, Genuine Disputes, Legal Entitlement, Labor & Employment Law, Evidence, Employee Burdens of Proof, Disabilities Under ADA, Mental & Physical Impairments, Major Life Activities, Mental & Physical Impairments, Substantial Limitations, Disability Discrimination, Circumstantial Evidence, Employment Practices, General Overview, Direct Evidence, Burden Shifting, Administrative Law, Judicial Review, Reviewability, Exhaustion of Remedies, Responses, Defenses, Demurrers & Objections, Business & Corporate Compliance, Discrimination, Federal & State Interrelationships