Weatherly v. Ford Motor Co., No. 20-1771 (8th Cir. 2021)
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Plaintiff filed suit against Ford under the Family and Medical Leave Act (FMLA), the Americans with Disabilities Act (ADA), and the Missouri Human Rights Act (MHRA), claiming that Ford terminated him twice and took other adverse employment action against him based on his asthma and scoliosis. The district court dismissed the FMLA claim as time-barred, and dismissed his ADA and MHRA claims on the ground that he exhausted his administrative remedies.
The Eighth Circuit concluded that FMLA claims were sufficient to survive a Federal Rule of Civil Procedure 12(b)(6) motion. The court also concluded that plaintiff has cleared the exhaustion hurdle on his MHRA claim but has pulled up short on his three ADA claims. Accordingly, the court affirmed in part and reversed in part.
Court Description: [Arnold, Author, with Smith, Chief Judge, and Stras, Circuit Judge Civil case - Americans with Disabilities Act. Plaintiff's allegations concerning FMLA claims were sufficient to survive a Rule 12(b)(6) motion, and the district court erred in dismissing the claims; the district court correctly held that plaintiff's ADA claims concerning an accommodation and discrimination were unexhausted and should be dismissed; however, plaintiff adequately alleged in his administrative charge that he was terminated because of his disability, and that termination claim was exhausted. [ April 16, 2021 ]
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