Walz v. Ameriprise Fin., Inc., No. 14-2495 (8th Cir. 2015)Annotate this Case
Walz worked for Ameriprise, 1996-2012 and received mostly positive reviews. Walz suffers from bipolar affective disorder, which, beginning in 2012, caused her to interrupt meetings, disturb her coworkers, and disrespect her supervisor, Radel. Radel approached Walz several times to discuss her behavioral problems and to offer help, before issuing a formal warning. Walz applied for Family Medical Leave Act (FMLA) leave, which was granted by a third-party administrator. Walz never disclosed the reason for her FMLA leave to Ameriprise. Upon returning from leave, Walz gave Radel a doctor’s note, clearing her to return to work and stating, “[s]he has been stabilizing on her medication.” Walz signed an Individual Treatment Policy, which explained Ameriprise’s policy against disability discrimination and the process for requesting accommodations. Months after returning to work, Walz’s erratic and disruptive behavior returned. Radel warned Walz, but Walz repeated her erratic and intimidating behavior in meetings. Ameriprise fired Walz because of her repeated misconduct. Walz never informed Ameriprise that she suffered from bipolar disorder or requested any accommodation. Walz sued, citing the Americans with Disabilities Act and the Minnesota Human Rights Act. The Eighth Circuit affirmed summary judgment, noting that Walz failed to establish that her termination was based on her disability and never requested an accommodation.