Naca v. Macalester College, No. 18-3264 (8th Cir. 2020)
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Plaintiff, an assistant professor at Macalester College, filed suit against the college after she was terminated for violating the college's policies on student-teacher relationships.
The Eighth Circuit affirmed the district court's dismissal of plaintiff's claims for discriminatory discharge based on disability under section 504 of the Rehabilitation Act of 1973, the Americans with Disabilities Act, and the Minnesota Human Rights Act (MHRA). The court held that plaintiff's claim regarding the departing provost was raised for the first time on appeal and therefore could not be considered by the court; the district court did not abuse its discretion in ruling that plaintiff's motion to amend her complaint to add claims under the Family Medical Leave Act was untimely and futile; and, even if plaintiff made a prima face case of discrimination, the court concluded on de novo review that the college articulated a legitimate, non-discriminatory reason for terminating plaintiff based on her sexual relationship with a former student. Finally, the court held that plaintiff's claim for failure to accommodate her disability under section 504 failed as a matter of law.
Court Description: Per Curiam - Before Smith, Chief Judge, and Gruender and Benton, Circuit Judges] Civil case - Americans with Disability Act. Argument that former provost had influenced the decision-makers who fired plaintiff was raised for the first time on appeal and would not be considered; assuming plaintiff made a prima facie case of discriminatory discharge based on sex, race/ancestry, religion and sexual orientation under Title IX, Section 1981, Title VII and the Minnesota Human Rights Act, the defendant articulated a legitimate, non-discriminatory ground for termination - violation of the school's policy on sexual relations with students - which plaintiff failed to counter with sufficient evidence of pretext; plaintiff admitted that she was able to perform the essential duties of her position with the accommodation provided, and this defeats her Rehabilitation Act claim as a matter of law.
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