Roby Anderson v. KAR Global, No. 22-2808 (8th Cir. 2023)
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Plaintiff appealed the district court’s adverse grant of summary judgment on his claims that his former employer, ADESA Missouri, LLC (ADESA), discriminated against and retaliated against him in violation of the Americans with Disabilities Act (ADA).
The Eighth Circuit reversed. The court concluded that Plaintiff produced sufficient evidence to raise a genuine issue of material fact as to whether ADESA’s reasons for terminating him were pretext for disability discrimination and retaliation. The court agreed with Plaintiff’s assertion that a reasonable jury could determine that the company’s VP made the decision to terminate Plaintiff because of his medical restriction and only retroactively claimed a performance-based concern after HR advised her that terminating an employee due to his disability could be “an issue.” The evidence shows that the VP sent an email to HR about an employee with a “medical restriction” who had been “identified” for termination, asking if this could be “an issue.” Only after she learned that it could be a problem did the VP respond with specific criticisms of his performance. ADESA argues that because Plaintiff does not dispute he was underperforming compared to his peers, there can be no pretext. But neither the sales director nor the VP was able to say when they took these performance assessments into consideration. Thus, the court concluded that Plaintiff has raised genuine doubt as to ADESA’s proffered reasons for his termination.
Court Description: [Kelly, Author, with Gruender and Arnold, Circuit Judges] Civil case - Americans with Disabilities Act. There was a genuine issue of material fact as to whether plaintiff had been terminated because of his disability and in retaliation for requesting an accommodation, and the district court erred in granting the employer's motion for summary judgment; the decision came ten days after the decision makers learned of plaintiff's disability, and this temporal proximity was sufficient to establish causation at the prima facie stage for plaintiff's disability and discrimination claims; further, a reasonable jury could conclude that the decision maker looked into plaintiff's job performance only after she had learned of his disability and accommodation request and had decided to terminate him; reversed and remanded for further proceedings.
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