Clark v. Champion National Security, Inc., No. 18-11613 (5th Cir. 2020)Annotate this Case
The Fifth Circuit affirmed the district court's grant of Champion's motion for summary judgment on workplace-discrimination claims brought by plaintiff, an employee, who alleged that he was fired because of a diabetes-related condition. Champion claimed that plaintiff was sleeping at his desk during work hours, an immediately terminable offense.
The court held that the district court did not err in finding no direct evidence of discrimination on the basis of disability. The court also agreed with the district court that the evidence suggested that plaintiff could not perform the essential functions of the job with or without an accommodation.
The court also held that plaintiff's disability-based claim failed because any harassment plaintiff alleged was not severe or pervasive and did not create an abusive working environment. Furthermore, plaintiff failed to show that the harassment was based on his disability. The court held that the district court did not err in finding no failure to accommodate plaintiff's disability and no failure to engage in an interactive process. Even if plaintiff was a qualified individual, his failure-to-accommodate claim failed because he failed to carry his burden to show that he requested reasonable accommodations. The court further held that plaintiff failed to show a prima facie case of retaliation. Finally, the district court did not err by denying plaintiff's claims for damages.