Caporicci v. Chipotle Mexican Grill, Inc.
189 F. Supp. 3d 1314
M.D. Fla.2016Background
- Lisa Caponed worked at Chipotle from July 2012 to June 7, 2013 and has a long history of bipolar disorder treated with medication; she experienced panic attacks and required brief leave to adjust medications.
- On May 30, 2013 a treating provider faxed Chipotle requesting FMLA leave through June 6, 2013 for severe panic attacks; Caponed was off May 30–June 3 and returned to work June 4.
- On June 7, 2013 Caponed took a new dose of Saphris, became dizzy and incoherent at work, was sent home, and later was terminated by manager Jared Miesel for appearing to be "under the influence of some kind of medication." Chipotle’s handbook contains a Drug and Alcohol Policy requiring employees to notify managers if prescribed drugs may impair work.
- Caponed filed an EEOC charge alleging ADA/ADAAA and FCRA disability discrimination and FMLA interference/retaliation; the EEOC issued a determination finding reasonable cause, and Caponed sued in federal court.
- Chipotle moved for summary judgment on all counts; the district court considered FMLA eligibility, whether Caponed had a disability under the ADAAA, and whether termination was nondiscriminatory or pretextual.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| FMLA eligibility / interference & retaliation | Caponed contends she requested FMLA leave and/or Chipotle should be estopped from denying eligibility | Chipotle argues Caponed lacked 12 months’ service and 1,250 hours at time leave began; no evidence of post-eligibility request or detrimental reliance for estoppel | Court: Caponed was not an "eligible employee" under FMLA; summary judgment for Chipotle on Counts I & II |
| ADA/FCRA — whether Caponed has a disability | Caponed asserts bipolar disorder and medication side effects substantially limit major life activities | Chipotle minimally contests disability under ADAAA but argues termination was for violating neutral drug/alcohol policy (nondiscriminatory) | Court: Under ADAAA, a genuine issue exists that bipolar disorder is a disability, but summary judgment still for Chipotle on discrimination claims |
| ADA/FCRA — whether termination was "because of" disability | Caponed argues termination was based on medication side effects (disability-related conduct) and manager failed to determine illegal drug use vs. prescription side effects | Chipotle argues conduct—being at work impaired by drugs—is a violation of neutral, generally applicable Drug and Alcohol Policy providing a legitimate nondiscriminatory reason | Court: Employer’s reliance on a neutral work rule provided a non-discriminatory reason; plaintiff failed to show pretext (no comparator, no evidence rule misapplied) |
| Pretext / adequacy of manager’s investigation | Caponed points to alleged cursory or dismissive conduct by manager (discarding fax; not investigating drug source) to show discriminatory intent | Chipotle contends the manager observed impairment, applied a zero-tolerance policy, and permitted leave earlier; a flawed investigation alone does not prove pretext | Court: Ham‑handed investigation and rude behavior insufficient to create inference of disability discrimination; summary judgment for Chipotle |
Key Cases Cited
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden allocations)
- Anderson v. Liberty Lobby, 477 U.S. 242 (genuine dispute and materiality standard for summary judgment)
- Raytheon Co. v. Hernandez, 540 U.S. 44 (neutral, generally applicable work rules as nondiscriminatory reason)
- Hurley v. Kent of Naples, Inc., 746 F.3d 1161 (FMLA eligibility elements)
- Cleveland v. Home Shopping Network, 369 F.3d 1189 (McDonnell Douglas framework for disparate-treatment ADA claims)