Murray v. Mayo Clinic, No. 17-16803 (9th Cir. 2019)
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The Ninth Circuit affirmed the district court's judgment for the Mayo Clinic in an action alleging employment discrimination under Title I of the Americans with Disabilities Act.
In light of Supreme Court precedent, the panel held that its decision in Head v. Glacier Northwest, Inc., 413 F.3d 1053 (9th Cir. 2005), holding ADA discrimination claims are evaluated under a motivating factor causation standard, is no longer good law. The panel held that Head was irreconcilable with the Supreme Court's decisions in Gross v. FBL Fin. Servs., Inc., 557 U.S. 167 (2009), and Univ. of Texas Southwestern Med. Ctr. v. Nassar, 570 U.S. 338 (2013). The panel agreed with its sister circuits and held that an ADA discrimination plaintiff bringing a claim under 42 U.S.C. 2112 must show that the adverse employment action would not have occurred but for the disability. Therefore, the district court correctly instructed the jury to apply a but for causation standard, rather than a motivating factor standard.
Court Description: Employment Discrimination The panel affirmed the district court’s judgment, after a jury trial, in favor of the defendants in an employment discrimination action under Title I of the Americans with Disabilities Act. The panel held that the district court correctly instructed the jury to apply a but for causation standard, rather than a motivating factor standard. The panel concluded that Head v. Glacier Northwest, Inc., 413 F.3d 1053 (9th Cir. 2005), holding that ADA discrimination claims are evaluated under a motivating factor causation standard, is no longer good law because its reasoning is clearly irreconcilable with the Supreme Court’s rulings in Gross v. FBL Fin. Servs., Inc., 557 U.S. 167 (2009), and Univ. of Texas Southwestern Med. Ctr. v. Nassar, 570 U.S. 338 (2013). Agreeing with other circuits, the panel held that an ADA discrimination plaintiff * The Honorable Benita Y. Pearson, United States District Judge for the Northern District of Ohio, sitting by designation. MURRAY V. MAYO CLINIC 3 bringing a claim under 42 U.S.C. § 12112 must show that the adverse employment action would not have occurred but for the disability. The panel addressed other issues in a simultaneously filed memorandum disposition.
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