EEOC v. Product Fabricators, Inc., et al., No. 13-2102 (8th Cir. 2014)
Annotate this CaseThe EEOC and Adam Breaux, a terminated employee of PFI, appealed the district court's adverse grant of summary judgment in favor of PFI. Breaux asserted that PFI discriminated against him based on his right shoulder injury and the district court erred in granting summary judgment on this claim. The court concluded that the year-long period that PFI accommodated Breaux's injury negated causation; and the casual, somewhat ambiguous conversation that took place in August 2009, does not establish a causal connection between Breaux's termination and his disability. Even if a prima facie case was established, because PFI has advanced a legitimate nondiscriminatory reason for terminating Breaux - poor performance - the burden shifted back to the EEOC and Breaux to show that PFI's proffered reason is pretext for intentional discrimination. In this case, the EEOC and Breaux failed to show pretext. Therefore, the district court correctly granted summary judgment on the Americans with Disabilities Act (ADA), 42 U.S.C. 12112(a), discrimination claim. Further, the district court properly granted summary judgment on the ADA failure-to-accommodate claim where Breaux failed to prove that he requested an accommodation. Because the district court properly dismissed the discrimination and retaliation claims, the court affirmed its dismissal of the successor liability claim. Accordingly, the court affirmed the judgment of the district court.
Court Description: Civil case - Employment discrimination. Even if plaintiff made a prima facie case that he was terminated on the basis of his disability, the defendant offered a legitimate, nondiscriminatory reason for the termination - poor performance -which plaintiff failed to show was a pretext for intentional discrimination; the record failed to show that plaintiff made a specific request for accommodation, and the district court did not err in granting defendant summary judgment on plaintiff's failure-to-accommodate discrimination claim; with respect to plaintiff's retaliation claims, he either did not engage in protected activity or failed to show a causal connection between the activity and the termination.
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