Hustvet v. Allina Health System, No. 17-2963 (8th Cir. 2018)
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The Eighth Circuit affirmed the district court's grant of summary judgment to Allina in an action brought by a former employer under the Americans with Disabilities Act (ADA) and the Minnesota Human Rights Act (MHRA), after she was terminated for refusing to fulfill a job requirement that she take necessary steps to develop immunity to rubella. The court held that, although the district court erred in denying plaintiff's inquiry claim based on a lack of injury, summary judgment was proper where Allina's decision to require employees with client contact to complete an inquiry and exam was job-related, consistent with business necessity, and no more intrusive than necessary. Therefore, the health screening that plaintiff was required to take as a condition of her employment complied with the ADA and the MHRA
The court also held that the evidence was insufficient to support plaintiff's claim that she was disabled under the ADA where the evidence was insufficient to support the conclusion that plaintiff's chemical sensitivities or allergies substantially or materially limited her ability to perform major life activities. Therefore, plaintiff's failure to accommodate claim failed. Likewise, her retaliation claim failed.
Court Description: Grasz, Author, with Loken and Erickson, Circuit Judges] Civil Case - Americans with Disabilities Act. The grant of summary judgment to the employer for terminating Hustvet for refusing to complete a Respirator Medical Evaluation form and for not taking the necessary steps to develop immunity to rubella as a condition of employment is affirmed. Although the district court erred in denying Hustvet's inquiry claim based on a lack of injury, summary judgment is nonetheless supported by the record because the decision to require a health screen was job-related and consistent with business necessity and did not violate the ADA or Missouri Human Rights Act. There was insufficient evidence to support Hustvet was disabled under the Act, and even if she were, her disability did not support a failure-to- accommodate claim. Hushvet's retaliation claim also fails as a matter of law.
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