Alice Mendoza v. Roman Cath. Archbishop of L.A.
824 F.3d 1148
| 9th Cir. | 2016Background
- Alice Mendoza worked full-time as a parish bookkeeper and took about ten months of medical leave.
- During her leave the pastor assumed bookkeeping duties and determined the work could be handled part time.
- When Mendoza was cleared to return to work she was offered a part-time position; she declined and sued under the ADA for failure to return her to a full-time role.
- The district court granted summary judgment for the defendant (the Archbishop/Archdiocese); Mendoza appealed.
- The Ninth Circuit assumed without deciding Mendoza was a qualified individual with a disability but reviewed de novo and affirmed summary judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Archbishop discriminated under ADA by not reinstating Mendoza to full-time work | Mendoza contends Archbishop’s refusal to restore full-time position was discriminatory and pretextual | Archbishop says legitimate nondiscriminatory reason: job was converted to part-time while Mendoza was on leave | Court: No triable issue of pretext; summary judgment for Archbishop affirmed |
| Whether disparate treatment standard requires only a motivating-factor showing post-Abercrombie | Mendoza relies on motivating-factor theory; cites Abercrombie | Archbishop argues Ninth Circuit precedent requires stronger proof for ADA disparate-treatment claims | Court: Abercrombie (Title VII) does not alter Ninth Circuit ADA precedent; Head remains good law here |
| Whether Archbishop failed to provide reasonable accommodation by not offering full-time work | Mendoza argues full-time position was a reasonable accommodation she needed | Archbishop argues no full-time position existed to accommodate her | Court: Mendoza failed to show an available reasonable accommodation; summary judgment affirmed |
| Whether identity of the employer (Archbishop vs. parish) matters to disposition | Mendoza may have alleged employer was Archbishop or parish | Archbishop notes uncertainty but argues decision does not hinge on employer identity | Court: Employer identity need not be decided for resolution; affirmed without resolving that question |
Key Cases Cited
- Snead v. Metro. Prop. & Cas. Ins. Co., 237 F.3d 1080 (9th Cir. 2001) (standard of review and summary judgment for ADA claims)
- Head v. Glacier Nw., Inc., 413 F.3d 1053 (9th Cir. 2005) (Ninth Circuit disparate-treatment framework for ADA claims)
- Pac. Shores Props., LLC v. City of Newport Beach, 730 F.3d 1142 (9th Cir. 2013) (disparate-treatment proof that discriminatory reason more likely than not motivated defendant)
- Dark v. Curry Cty., 451 F.3d 1078 (9th Cir. 2006) (plaintiff bears burden to show existence of reasonable accommodation that would permit performance of essential job functions)
- EEOC v. Abercrombie & Fitch Stores, Inc., 135 S. Ct. 2028 (2015) (Title VII motivating-factor holding; knowledge not required for failure-to-accommodate claim; distinguished from ADA context in this opinion)