AMY BUCHANAN V. WATKINS & LETOFSKY, LLP, No. 21-15633 (9th Cir. 2022)
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Plaintiff filed suit against defendant, a Nevada limited liability partnership (“W&L Nevada”) under the Americans with Disabilities Act (“ADA”). The district court granted summary judgment for W&L Nevada on plaintiff’s ADA claims. The district court held that, as a matter of law, W&L Nevada was not a covered employer under the ADA because (1) it had fewer than 15 employees and (2) plaintiff did not present sufficient evidence to create a genuine issue of material fact whether W&L Nevada was an “integrated enterprise” with W&L California.
The circuit court held that even when a defendant has fewer than 15 employees, a plaintiff can bring a statutory claim if she can establish that (1) defendant is “so interconnected with another employer that the two form an integrated enterprise” and (2) the integrated enterprise collectively has at least 15 employees. Here, the circuit court found that plaintiff established a genuine issue of material fact regarding whether defendant’s two offices were an integrated enterprise. Further, defendant did not present evidence that the Nevada and California offices were separate operations and maintained separate books. Accordingly, the circuit court reversed the district court’s grant of summary judgment for defendant on plaintiff’s ADA claims. Further, the circuit court remanded the district court to address whether the integrated enterprise had fewer than 15 employees.
Court Description: Americans with Disabilities Act The panel reversed the district court’s summary judgment in favor of defendant Watkins & Letofsky, a Nevada limited liability partnership, in an action brought by Amy Buchanan alleging employment discrimination and retaliation under the Americans with Disabilities Act. The district court concluded that the ADA did not apply to W&L Nevada because it had fewer than 15 employees. The panel held that because Title VII and the ADA include the same 15-employee threshold and statutory enforcement scheme, the integrated enterprise doctrine applicable in Title VII cases applies equally under the ADA. Under this doctrine, a plaintiff can bring a claim if she can establish that the defendant is so interconnected with another employer that the two form an integrated enterprise, and the integrated enterprise collectively has at least 15 employees. Daniel Watkins and Brian Letofsky, who were licensed to practice in Nevada and California, owned and were the only partners of W&L Nevada. Likewise, they owned and were the only partners of Watkins & Letosfsky, a California limited liability partnership. Considering factors of interrelation of operations, common management, centralized control of labor relations, and common ownership or financial control, the panel concluded that Buchanan established a genuine issue of material fact whether W&L’s two offices were an integrated enterprise. BUCHANAN V. WATKINS & LETOFSKY 3 The panel reversed and remanded for the district court to consider in the first instance whether, even if W&L Nevada and W&L California were an integrated enterprise, they together had fewer than 15 employees.
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