Snapp v. BNSF Railway Co., No. 15-35410 (9th Cir. 2018)Annotate this Case
The Ninth Circuit affirmed the district court's judgment in favor of BNSF in an action alleging a failure to accommodate plaintiff under the Americans with Disabilities Act (ADA). Applying de novo review, the panel held that it was neither appropriate nor necessary to extend the Barnett and Morton burden-shifting framework to trial. The panel reasoned that the consequences of the denial of summary judgment was not a meaningless gesture, and when weighed against the confusion and complexity likely to arise at trial, burden shifting was best confined to summary judgment. The panel held that the district court properly described plaintiff's burden as a burden of proof and properly refused his requested instruction. Finally, the district court did not err in denying plaintiff's motion for judgment as a matter of law.