Tramp v. Associated Underwriters, Inc., No. 13-2546 (8th Cir. 2014)Annotate this Case
Plaintiff filed suit against Associated Underwriters after she was terminated, alleging claims under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq., and the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. The district court dismissed both claims. The court concluded that plaintiff presented sufficient evidence to allow a reasonable jury to conclude that there was a direct correlation between employee age and the termination decision - that it was the but-for cause of plaintiff's termination. Therefore, the court reversed the district court's dismissal of the ADEA claim. The court concluded, however, that the district court properly dismissed the ADA claim where there is no evidence that Associated Underwriters terminated her employment on the basis of disability. Therefore, the court affirmed as to this claim.
Court Description: Civil case - Employment discrimination. A genuine issue of fact was present as to whether plaintiff's age was the "but-for" cause of her termination, and the district court erred in granting the employer summary judgment on plaintiff's ADEA claim; as a matter of law, plaintiff's ADA claim failed because there is no evidence that the employer terminated her employment on the basis of disability.