Law School Case Brief
Walter v. Wal-Mart Stores - 2011 U.S. Dist. LEXIS 112185 (N.D. Ind. Sep. 28, 2011)
Summary judgment is proper where the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and the moving party is entitled to judgment as a matter of law. Fed. R. Civ. P. 56(c). A "material" fact is one identified by the substantive law as affecting the outcome of the suit. A "genuine issue" exists with respect to any such material fact, and summary judgment is therefore inappropriate, when the evidence is such that a reasonable jury could return a verdict for the non-moving party. On the other hand, where a factual record taken as a whole could not lead a rational trier of fact to find for the non-moving party, there is no genuine issue for trial.
On Feb. 23, 2009, plaintiff John A. Walter filed a complaint in federal district court alleging that defendant, Wal-Mart Stores Inc. ("Wal-Mart") failed to make reasonable accommodations and terminated his employment in violation of the Americans with Disabilities Act ("ADA") and in violation of an Indiana Civil Rights law prohibiting disability discrimination in employment. According to Wal-Mart, Walter's employment was terminated for failure to produce requested medical documents that Wal-Mart needed to process his reasonable accommodation request associated with one of his job tasks—processing customer returns. Wal-Mart filed a motion for summary judgment.
Was Wal-Mart entitled to summary judgment?
The court granted Wal-Mart's motion for summary judgment. The court agreed with Wal-Mart that Walter's federal claim incorporated both a failure to accommodate and a disparate treatment claim under the ADA. Because Walter failed to show that a triable issue existed with respect to a threshold requirement common to both types of claim, summary judgment with respect to that claim was warranted. Because Walter failed to establish a jurisdictional basis for the court to hear his state law disability claim, that claim was dismissed without prejudice.
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