Howard v. Steris Corp., 886 F. Supp. 2d 1279

Background

Howard, employed by STERIS since 1985, worked in the Case Work Department on an assembly cell assembling warming cabinets.
STERIS had an Employee Handbook with discrimination, ADA, and accommodation policies, including a two-supervisor confirmation rule for sleeping on the job and flexible disciplinary application by final decision-maker McBride.
Howard has long-standing sleep-related issues; diagnoses include Graves’ disease and obstructive sleep apnea, but no narcolepsy diagnosis was given by treating physicians.
In June 2009, STERIS initiated a reduction-in-force program targeting long-tenured employees; Howard was eligible but allegedly did not volunteer before the deadline according to company; Howard claims timing was later.
Howard was caught sleeping at his workstation on June 11, 2009; he was suspended and then fired following the investigation by a group including McBride, Thomas, Williams, and Bridges, with McBride unaware of narcolepsy at the time.
Howard pursued unemployment benefits; the ADIR denied benefits after finding he violated work rules by sleeping on the job.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Collateral estoppel applicability	ADIR findings not reviewable; unreviewed decisions can preclude ADA/ADEA claims.	Unreviewed state agency findings should preclude federal claims under some contexts.	Collateral estoppel denied; unreviewed agency findings do not preclude Howard's ADA/ADEA claims.
ADA disparate treatment	Howard was fired due to disability; knowledge of disability by decisionmakers is present.	No actual knowledge of disability by decisionmakers; firing for sleeping on the job was legitimate.	Granted in favor of STERIS; no genuine issue of fact on disability knowledge or discrimination.
ADA failure to accommodate	Employer failed to provide reasonable accommodations (early retirement, FMLA, ongoing wake-up accommodations).	No trigger for accommodation absent a specific request; accommodations not demanded by Howard.	Summary judgment for STERIS; no valid accommodation request or duty to initiate interactive process.
ADA retaliation	Firing retaliation for seeking unemployment benefits/complaining about treatment.	No direct or indirect evidence of retaliation; action based on sleeping on the job.	Summary judgment for STERIS on retaliation claim.
ADEA age discrimination	Firing Howard was motivated by age; others younger rotated into his cell; early retirement plan targeted older employees.	Company’s reasons were non-discriminatory and not age-biased; there is no replacement with substantially younger worker.	STERIC’s reasons non-discriminatory; no but-for causal link shown between age and firing.

Key Cases Cited

Morisky v. Broward County, 80 F.3d 445 (11th Cir.1996) (actual knowledge required for ADA notice; vague statements insufficient)
Cordoba v. Dillard's, Inc., 419 F.3d 1169 (11th Cir.2005) (discrimination requires actual knowledge, not constructive)
Astoria Federal Savings & Loan v. Solimino, 501 U.S. 104 (Supreme Court 1991) (unreviewed administrative decisions and preclusion under ADEA)
University of Tennessee v. Elliott, 478 U.S. 788 (Supreme Court 1986) (Congress overrides state findings in Title VII deferral; limits preclusion)
Pernice v. City of Chicago, 237 F.3d 783 (7th Cir.2001) (ADA deferral procedures mirror Title VII for preclusion analysis)
St. Mary’s Honor Ctr. v. Hicks, 509 U.S. 502 (Supreme Court 1993) (burden-shifting framework and pretext evaluation)
Gross v. FBL Fin. Servs., Inc., 557 U.S. 167 (Supreme Court 2009) (but-for cause standard for ADEA disparate treatment)
Hill v. Kansas City Area Transp. Auth., 181 F.3d 891 (8th Cir.1999) (distinguishes knowledge of disability vs. limitations)