Walz v. Ameriprise Fin., Inc., No. 14-2495 (8th Cir. 2015)
Annotate this CaseWalz 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.
Court Description: Civil case - Employment discrimination. Plaintiff failed to show she was a qualified individual for ADA purposes;her behavioral issues stemming from her bipolar disorder prevented her from being able to work with others, an essential function of her position, and she could not make a sufficient showing that she was able to perform the essential function of her position without an accommodation; while an employee may be qualified under the ADA if a reasonable accommodation would allow her to perform the essential functions of her position, plaintiff failed to inform defendant of her disability or request an accommodation, and defendant had no duty to accommodate her; nor was her disability and its limitations open and obvious to the defendant, so she could not establish a genuine issue of material fact as to whether she was able to perform the essential functions of her job with a reasonable accommodation; plaintiff failed, therefore to make a prima facie case of wrongful termination.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.