538 F.Supp.3d 1344
M.D. Ga.2021Background:
- Champion worked as a Quality Assurance Technician at Mannington Mills; her brother Alvin Evans also worked at the same facility.
- On March 26, 2020, Champion spoke with Evans for a few minutes in the parking lot; Evans later felt ill, was tested, and on March 30 tested positive for COVID-19.
- Champion initially did not disclose the parking‑lot encounter when asked by HR, later recounted it after being confronted by her supervisor, and was sent home to quarantine and then terminated.
- Champion alleges she was singled out because she was related to Evans, treated as "diseased," denied leave/work options others received, and was not in CDC‑defined close contact with Evans.
- Champion filed an EEOC charge and sued under the ADA for discrimination based on association with a person with a known disability; Mannington moved to dismiss under Rule 12(b)(6) arguing Champion failed to plead that Evans was a "disabled" person under the ADA.
- The court granted Mannington's motion and dismissed Champion's complaint for failure to allege that Evans met the ADA's definition of "disability."
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Evans' COVID‑19 qualifies as a "disability" under 42 U.S.C. § 12102(1) | Champion: alleging Evans had COVID‑19 and that COVID‑19 can substantially limit major life activities suffices at the pleading stage | Mannington: complaint lacks factual allegations showing Evans was substantially limited in any major life activity | Held: Dismissed — plaintiff failed to allege specific facts showing Evans was disabled under the ADA (mere infection and a short absence from work insufficient) |
| Whether an association‑discrimination claim can be predicated on association with someone "regarded as" disabled | Champion: association claim should be available even if the associated person was only "regarded as" disabled | Mannington: association claim requires the associated person be a known disability (not merely regarded as disabled); employer actions following public‑health guidance do not show it regarded Evans as disabled | Held: Court rejected using the "regarded as" prong to support association discrimination and, in any event, found no facts showing Mannington regarded Evans as disabled |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading standard requires plausibility)
- Ashcroft v. Iqbal, 556 U.S. 662 (courts disregard conclusory allegations and apply two‑step plausibility test)
- McCullough v. Finley, 907 F.3d 1324 (11th Cir.) (application of Twombly/Iqbal in this circuit)
- Hilburn v. Murata Electronics of North America, Inc., 181 F.3d 1220 (11th Cir. 1999) (alleged diagnosis alone insufficient to show substantial limitation)
- E.E.O.C. v. STME, LLC, 938 F.3d 1305 (11th Cir. 2019) (association‑discrimination requires a known disability; merely "regarded as" is not a basis for association claim)