Guardarrama v. Municipality of Aguas Buenas
3:10-cv-02254
D.P.R.Nov 8, 2012Background
- Plaintiff Jose Guardarrama sues Municipality of Aguas Buenas under the ADA and Law 80 alleging disability discrimination and failure to provide reasonable accommodation.
- Plaintiff claims harassment by coworker Rosario worsened his disability and he sought separation from Rosario as accommodation.
- Defendants Municipality, Ortiz Reyes, and Arroyo move for summary judgment; joinder of Ortiz and Arroyo.
- Court applies Rule 56 standard and reviews uncontested facts and record evidence.
- Court finds genuine issues of material fact exist; summary judgment denied on ADA and Law 80 claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is Guardarrama disabled and entitled to reasonable accommodation under the ADA? | Guardarrama is disabled and needed accommodation. | Municipality argues no valid accommodation was requested/needed. | Triable issue; not entitled to summary judgment. |
| Did the Municipality have knowledge of the disability and fail to accommodate? | Municipality knew of disability and inadequately responded. | No proper notice or notification of needed accommodation. | Triable issue; not entitled to summary judgment. |
| Was separating Guardarrama from Rosario a reasonable accommodation or undue hardship? | Separation was a reasonable accommodation. | No clear, proper accommodation; undue hardship potential. | Triable issue; not entitled to summary judgment. |
Key Cases Cited
- Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. 1986) (burden to show absence of genuine issue of material fact)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. 1986) (genuine dispute requires jury could return a verdict for nonmoving party)
- Griggs-Ryan v. Smith, 904 F.2d 112 (1st Cir. 1990) (courts may ignore conclusory allegations in summary judgment)
- Santiago-Ramos v. Centennial P.R. Wireless Corp., 217 F.3d 46 (1st Cir. 2000) (burden on opposing party to show genuine issue exists)
- Maldonado-Denis v. Castillo-Rodriguez, 23 F.3d 576 (1st Cir. 1994) (opposing party must present definite, competent evidence)
- Estades-Negroni v. The Associates Corp. of N.A., 377 F.3d 58 (1st Cir. 2004) (elements for ADA reasonable accommodation claim)
- Santiago-Ramos v. Centennial P.R. Wireless Corp., 217 F.3d 46 (1st Cir. 2000) (summary judgment framework)