MATTIODA V. NELSON, No. 22-15889 (9th Cir. 2024)
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A scientist with physical disabilities, Dr. Andrew Mattioda, sued his employer, the National Aeronautics and Space Administration (NASA), under the Rehabilitation Act of 1973. He alleged that he suffered a hostile work environment after informing his supervisors of his disabilities and requesting upgraded airline tickets for work travel. He also claimed he was discriminated against due to his disability by being passed over for a promotion.
The United States District Court for the Northern District of California dismissed Dr. Mattioda’s hostile-work-environment claim and granted summary judgment in favor of NASA on his disability-discrimination claim. The court concluded that Dr. Mattioda failed to allege a plausible causal nexus between the claimed harassment and his disabilities. It also held that NASA provided a legitimate nondiscriminatory reason for not selecting Dr. Mattioda for an available senior scientist position.
On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s dismissal of Dr. Mattioda’s hostile-work-environment claim, affirming that a disability-based harassment claim is available under the Americans with Disabilities Act of 1990 and the Rehabilitation Act. The court held that Dr. Mattioda plausibly alleged a hostile-work-environment claim based on his disability. However, the court affirmed the district court’s order granting summary judgment for NASA on the disability-discrimination claim, agreeing that NASA had provided a legitimate nondiscriminatory reason for not selecting Dr. Mattioda for the senior scientist position. The case was remanded for further proceedings.
Court Description: Employment Law The panel reversed the district court’s dismissal of Dr. Andrew Mattioda’s hostile-work-environment claim, affirmed the district court’s summary judgment in favor of his employer the National Aeronautics and Space Administration (“NASA”) on his disability-discrimination claim, and remanded for further proceedings.
Dr. Mattioda, a scientist with NASA, has physical disabilities related to his hips and spine that he alleged required him to purchase premium-class airlines tickets for flights over an hour long. He sued NASA under the Rehabilitation Act of 1973, alleging that he suffered a hostile work environment after informing his supervisors of his disabilities and requesting upgraded airline tickets for work travel, and alleging he was discriminated against due to his disability by being passed over for a promotion.
Addressing the hostile-work-environment claim, the panel held that a disability-based harassment claim is available under the Americans with Disabilities Act of 1990 and the Rehabilitation Act. Turning to the merits of Dr. Mattioda’s claim, the panel held that the district court correctly applied the Iqbal/Twombly standard in assessing his complaint. The district court erred, however, in concluding that Dr. Mattioda failed to allege a plausible causal nexus between the claimed harassment and his disabilities. The panel also rejected NASA’s argument that Dr. Mattioda’s hostile-work environment claim failed on the alternative ground that he did not allege sufficiently severe or pervasive harassment. The panel concluded that Dr. Mattioda alleged sufficiently severe or pervasive harassment to survive NASA’s motion to dismiss, and plausibly alleged a hostile-work environment claim based on his disability.
Addressing the disability-discrimination claim, the panel held that the district court correctly applied the McDonnell Douglas burden-shifting framework in assessing Dr. Mattioda’s claim. Even assuming that Dr. Mattioda established a prima facie case of disability discrimination, NASA proffered a legitimate nondiscriminatory reason for not selecting Dr. Mattioda for an available senior scientist position. Accordingly, the district court did not err in granting summary judgment to NASA on this claim.
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