105 F.4th 856
6th Cir.2024Background
- Benjamin Stanley worked at Western Michigan University (WMU) as a utility food worker for 31 days before being terminated for excessive tardiness and improper clocking-in.
- Stanley, who has severe ADHD, requested reasonable accommodations for his disability (e.g., an alternative method for clocking in and permission to use his service dog), which WMU denied.
- After termination, Stanley filed suit against WMU and several supervisors, alleging discrimination and retaliation under the ADA, violations of Michigan's PWDCRA, and intentional infliction of emotional distress.
- The district court dismissed the ADA claims for lack of subject-matter jurisdiction (Eleventh Amendment immunity) and the state-law claims for failure to comply with state procedural requirements; leave to amend the complaint was also denied.
- On appeal, the Sixth Circuit affirmed dismissal of the federal claims (and denial of leave to amend) but remanded with instructions to dismiss all claims without prejudice due to lack of jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ADA Title I Discrimination Claim (against WMU) | WMU discriminated by firing him due to disability and denying accommodation | WMU is immune under the Eleventh Amendment; no jurisdiction for such a suit | Dismissed for lack of jurisdiction due to sovereign immunity; not allowed |
| ADA Title V Retaliation Claim (against WMU) | Fired in retaliation for seeking accommodation (protected activity under ADA) | Sovereign immunity not abrogated for Title V ADA claims based on Title I violations | Dismissed for lack of jurisdiction; Congress did not validly abrogate immunity |
| State Law Claims (PWDCRA, IIED) | PWDCRA and emotional distress claims viable under Michigan law | Failure to comply with Michigan notice requirements and no supplemental jurisdiction | Dismissed; federal court lacks supplemental jurisdiction after dismissal of federal claims |
| Leave to Amend Complaint | Amendment would cure deficiencies, support Ex parte Young exception for prospective relief | Amendment would be futile; facts and law cannot cure jurisdictional bar | Denial of leave affirmed; amendment futile as it would not survive motion to dismiss |
Key Cases Cited
- Bd. of Trs. of Univ. of Ala. v. Garrett, 531 U.S. 356 (Supreme Court held states are immune from ADA Title I claims for damages)
- Tennessee v. Lane, 541 U.S. 509 (Ex parte Young permits only prospective injunctive relief against state officials)
- Kimel v. Fla. Bd. of Regents, 528 U.S. 62 (Explains Congress’s §5 Fourteenth Amendment power to abrogate state immunity)
- Catlin v. United States, 324 U.S. 229 (Defines when a district court order is final for appeal purposes)