Law School Case Brief
Smith v. Midland Brake, Inc. - 180 F.3d 1154 (10th Cir. 1999)
After considering the submissions by both sides on summary judgment, if there remains genuine evidence supporting each element of the employee's prima facie case and, if need be, disputing the employer's affirmative defenses, summary judgment for the employer should be denied and the matter must proceed to trial.
Plaintiff-Appellant Robert Smith was employed by Defendant-Appellee Midland Brake for nearly seven years in the light assembly department. Through this job, Smith came into contact with various chemicals, solvents, and irritants. He eventually developed muscular injuries and chronic dermatitis that caused him to become permanently disabled and unfit to work in the light assembly department. Midland Brake was unable to find an assignment within the light assembly department that Smith could perform given his physical limitations, and eventually, Smith was fired. Consequently, Smith filed a complaint seeking relief on the basis of Midland Brake’s alleged violation of Americans with Disabilities Act (ADA) and various other statutes. The district court entered summary judgment for Midland Brake on all of these claims. With regard to the ADA claim in particular, the district court held that Smith was not a "qualified individual with a disability" because, inter alia, Smith failed to provide Midland Brake with a medical release to return to work. Smith challenged the decision of the District Court.
Did the fact of plaintiff employee's inability to perform his current job preclude his ADA claim for an accommodation of reassignment, thereby justifying the grant of summary judgment in favor of defendant employer Midland Brake?
On appeal, the circuit court of appeals reversed and remanded. The court reasoned that even though Smith was admittedly unable to perform the essential functions of his existing job in the light assembly department, such admission alone did not preclude his ADA claim for an accommodation of reassignment. A person must meet the threshold test of being a "qualified individual with a disability" in order to invoke the ADA. Although a "qualified individual with a disability" has to be someone who can perform the essential functions of a job, that inquiry was not limited to the employee's existing job. Rather, the plain language of the statute included an employee who has the ability to do other jobs within the company that such disabled employee "desires." The Court averred that to read the Americans with Disabilities Act otherwise, would render the word "desires" meaningless. Because genuine issues of material fact existed in this regard, summary judgment was premature. The record established a genuine dispute of material fact regarding whether Smith sufficiently invoked the ADA's interactive process and, if so, whether Midland Brake adequately responded to a request for reassignment.
As for the applicable standards: The appellate court reviews the district court's grant of summary judgment de novo. In determining whether the evidence presents a genuine issue of material fact, the appellate court views it in the light most favorable to the party against whom summary judgment is entered. The McDonnell Dougls burden shifting approach in the context of summary judgment has been specifically adopted to ADA claims for failure reasonably to accommodate the disabled employee.
Access the full text case
Not a Lexis+ subscriber? Try it out for free.
Be Sure You're Prepared for Class