Law School Case Brief
Mazzeo v. Color Resolutions Int'l, LLC - 746 F.3d 1264 (11th Cir. 2014)
The Americans with Disabilities Act (ADA) prohibits discrimination by an employer against a qualified individual on the basis of a disability in any of the terms, conditions, or privileges of employment, 42 U.S.C.S. § 12112(a). A "qualified individual" is an individual who, with or without reasonable accommodation, can perform the essential functions of the employment position that such individual holds or desires, 42 U.S.C.S. § 12111(8). To establish a prima facie case of employment discrimination under the ADA, a plaintiff must show that, at the time of the adverse employment action, he had a disability, he was a qualified individual, and he was subjected to unlawful discrimination because of his disability.
In 2004, Color Resolutions International, LLC (CRI) hired Anthony Mazzeo to provide technical and sales service to its customers in Florida and southern Georgia. In 2007, Mazzeo was diagnosed with a herniated disc and torn ligaments in his back. The herniated disc caused pain along Mazzeo's lower back, which down radiated down his right leg and intermittently affected his ability to walk, sit, stand, bend, run, and lift objects weighing greater than 10 pounds. In October of 2008, Mazzeo first discussed his condition with his supervisor at CRI, Hixon Boyd, and with the supervisor of human resources at CRI, Phyllis Arellano. Between January and March of 2009, Mazzeo had at least three discussions with Boyd regarding his possible back surgery, which would require him to miss two weeks of work and have three to six months of restricted activity. Supervisor Boyd was alleged to have remarked, whether in concern for Mazzeo's well-being or out of a self-serving business interest, that such a surgical procedure would likely require a longer recovery period of six to eight weeks. On February 25, 2009, Mazzeo informed Boyd that his back surgery had been scheduled for the second week of March. The very next day, Boyd initiated the paperwork for Mazzeo's termination. According to CRI, the reason for the termination was the declining sales revenue, over a period of several years, in Mazzeo's Florida territory. Supervisor Boyd handed the termination papers to Mazzeo two days before his scheduled surgery. When CRI terminated him on March 10, 2009, Mazzeo was 46 years old. Ten days after Mazzeo's termination, CRI offered a similar sales position to a 23-year-old recent college graduate. Mazzeo sued CRI, claiming discrimination under the Americans with Disabilities Act of 1990, 42 U.S.C. § 12101 et seq. (ADA), the Age Discrimination and Employment Act of 1967, 29 U.S.C. § 621 et seq. (ADEA), and the Florida Civil Rights Act, Fla. Stat. § 760.10 (FCRA). The district court granted summary judgment in favor of CRI. With respect to the disability claims, the district court concluded that Mazzeo did not present a prima facie case because he failed to show that he either suffered from a disability or was regarded by CRI as having a disability. As to the age discrimination claims, the district court ruled that Mazzeo failed to state a prima facie case pursuant to a reduction-in-force theory.
Did plaintiff Mazzeo fail to state a prima facie claim discrimination case against his former employer?
The Court of Appeals for the Eleventh Circuit held that the evidence was enough for Mazzeo to present a prima facie case of disability under the ADA and the FCRA, given the new standards and definitions put in place by the ADA Amendments Act of 2008. Moreover, the Eleventh Circuit held that Mazzeo presented evidence which, viewed in the light most favorable to Mazzeo, suggested that he was replaced shortly after his termination by a younger person, and on remand, the district court must use the standard version of the ADEA prima facie case in evaluating Mazzeo’s motion for summary judgment.
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