Joseph Mobley v. St. Luke's Health System, Inc., No. 21-2417 (8th Cir. 2022)
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Plaintiff sued St. Luke’s pursuant to the Americans with Disabilities Act (“ADA”), the Missouri Human Rights Act (“MHRA”), Title VII of the Civil Rights Act of 1964, and 42 U.S.C. Section 1981. Plaintiff alleged that St. Luke’s: discriminated against him on the basis of his disability, gender, and race; failed to accommodate him; and retaliated against him. St. Luke’s sought summary judgment on all issues, and the district court granted St. Luke’s motion. Plaintiff appealed the district court’s ruling regarding only his claims of disability discrimination under the MHRA and failure to accommodate under the ADA and the MHRA.
The Eighth Circuit affirmed. The court explained that the record demonstrates several steps that St. Luke’s took in response to Plaintiff’s request for accommodation. Thus, because there is no triable issue as to whether St. Luke’s acted in good faith, the court wrote it need not reach the final step of the analysis, which is whether St. Luke’s could have reasonably accommodated Plaintiff. Accordingly, the court affirmed summary judgment on Plaintiff's failure-to-accommodate claim. Likewise, in opposing St. Luke’s motion for summary judgment before the district court, Plaintiff failed to argue his constructive discharge claim.
Court Description: [Menendez, Author, with Loken and Kelly, Circuit Judges] Civil case - Employment Discrimination. A genuine issue of material fact existed as to whether plaintiff was able to perform the essential functions of his job through his proposed accommodation of teleworking when he experienced a flareup of his medical condition, and the district court erred in concluding he had failed to demonstrate that he could perform the essential job functions with or without a reasonable accommodation; while plaintiff made a prima facie case of disability discrimination he did not establish that defendant failed to engage in the interactive process in good faith; as a result the district court did not err in granting defendant summary judgment on plaintiff's failure-to-accommodate claim; plaintiff failed to raise his constructive-discharge claim before either the EEOC or the district court, and it was not properly before this court.
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