Voss v. Housing Authority of the City of Magnolia, No. 17-1650 (8th Cir. 2019)
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The Eighth Circuit affirmed the district court's grant of summary judgment for the Housing Authority and plaintiff's supervisor in an action alleging various discrimination, retaliation, and constitutional claims. Plaintiff resigned from his job after he failed a drug test and his employer sought documentation of the prescription medications plaintiff was using, as well as a clearance letter from plaintiff's healthcare professionals addressing the issue.
The court held that, by not including in his EEOC charge the adverse acts which he maintained forced him to resign, plaintiff failed to administratively exhaust his constructive discharge allegation; plaintiff failed to establish a prima facie case of disability discrimination; plaintiff failed to show that he suffered an adverse employment action because he was suspended before his employer had any reason to suspect that he might be disabled; and plaintiff failed to show that he possessed a property interest in his employment under Arkansas law in order to prevail on his procedural due process claim.
Court Description: Grasz, Author, with Colloton and Gruender, Circuit Judges] Civil case - Employment discrimination. By not including in his EEOC charge the adverse acts plaintiff claims forced him to resign, he failed to administratively exhaust his constructive discharge claim; the district court properly granted summary judgment to defendant on plaintifff's disability discrimination claim because he did not establish a prima facie case of discrimination; plaintiff failed to show he suffered an adverse employment action, a required element of a prima facie case, because he was suspended before his employer had any possible reason to suspect he might be disabled; plaintiff's procedural due process claim failed because as an at-will employee he did not have a property interest in continued employment.
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