Thompson v. Gold Medal Bakery, Inc., No. 20-1027 (1st Cir. 2021)
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The First Circuit affirmed the judgment of the district court granting summary judgment to Gold Medal Bakery, Inc. and dismissing Robert Thompson's claims brought after he was fired, holding that the district court did not err or abuse its discretion.
After he was fired, Thompson brought this complaint alleging that Gold Medal terminated his employment in violation of the anti-retaliation provision of the Family and Medical Leave Act (FMLA) and federal and state disability discrimination laws. The district court granted summary judgment to Gold Medal on all claims. The First Circuit affirmed, holding (1) the district court properly determined that, as a matter of law, Thompson could not establish that he was a "qualified individual" under the Americans with Disabilities Act at the time of his firing; (2) the district court did not err in granting summary judgment to Gold Medal on Thompson's FMLA retaliation claim; and (3) Thompson's remaining arguments were unavailing.
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