Michael Winters v. Deere & Company, No. 22-1035 (8th Cir. 2023)Annotate this Case
Plaintiff was fired by John Deere & Co.; he sued Deere for failing to accommodate his disability and discriminating against him in violation of the Iowa Civil Rights Act (ICRA). The district court granted summary judgment to Deere. Plaintiff appealed the district court’s judgment on his disability and failure to accommodate claims.
The Eighth Circuit affirmed. The court explained that Plaintiff cannot make a prima facie case for failure to accommodate because he never requested an accommodation at the relevant time. In fact, Deere encouraged Plaintiff to request accommodations and accommodated him before when he asked. And when Plaintiff returned to work in September 2019, he had been cleared of all restrictions. Because Plaintiff has not shown that Deere knew he needed an accommodation on his return to work, his claim fails. Further, the court wrote that Plaintiff has not provided any direct evidence of discrimination that “shows a specific link between the alleged discriminatory animus and the challenged decision, sufficient to support a finding by a reasonable fact finder that an illegitimate criterion actually motivated the adverse employment action.” Finally, the court held that Plaintiff’s suggestion that his actions weren’t serious enough to merit his termination “merely questions the soundness of [Deere’s] judgment, and does not demonstrate pretext for discrimination.”
Court Description: [Kobes, Author, with Kelly and Wollman, Circuit Judges] Civil case - Employment discrimination. Plaintiff cannot make a prima facie case of failure to accommodate his disability as he never requested an accommodation at the relevant time; plaintiff failed to provide any direct evidence of disability-based discrimination; with respect to the McDonnell Douglas framework, assuming plaintiff can make a prima facie case of disability-based discrimination, defendant established a legitimate non-discriminatory ground for plaintiff's termination, which he failed to show was pretextual.