Jeffrey Atkins v. Eric Holder, 529 F. App'x 318

Atkins, a former Bureau of Prisons correctional counselor, challenges summary judgment on disability discrimination under the Rehabilitation Act, and racial and retaliation claims under Title VII, plus age discrimination under the ADEA.
Atkins suffered from polyarthropathy of the right knee and degenerative disc disease, with doctors imposing permanent restrictions on activity.
The correctional counselor role is a law enforcement position requiring physical restraint of inmates; Atkins’ restrictions were severe enough that no accommodation could render him qualified for the job.
The district court held Atkins not qualified for disability discrimination and granted summary judgment on all claims.
On appeal, the Fourth Circuit reviews de novo and construes facts in Atkins’ favor for summary judgment determinations.
The district court remanded only a breach-of-contract claim to state court; federal claims were resolved with an affirmance of summary judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Disability discrimination under the Rehabilitation Act	Atkins was disabled and otherwise qualified; discrimination occurred due to disability.	Atkins was not qualified due to medical restrictions preventing essential duties; no reasonable accommodation could suffice.	Atkins not qualified; no prima facie disability discrimination.
Race discrimination under Title VII (disparate treatment)	Comparator evidence and pretext show discriminatory termination.	Proffered reason (inability to perform duties) is legitimate; no discriminatory motive shown.	No prima facie case; insufficient evidence of pretext; no discriminatory termination established.
Retaliation under Title VII	Termination after protected activity shows causal link and pretext not proven.	Temporal gap weakens causation; other evidence insufficient to prove retaliation.	No prima facie case for retaliation; no causal connection shown.

Doe v. Univ. of Md. Med. Sys. Corp., 50 F.3d 1261 (4th Cir. 1995) (disability discrimination requires disability, qualification, and discrimination solely due to disability)
Tyndall v. National Educ. Centers, Inc. of California, 31 F.3d 209 (4th Cir. 1994) (definition of a qualified individual with a disability)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (Supreme Court 1973) (burden-shifting framework for discrimination cases)
Tex. Dept. of Cmty. Affairs v. Burdine, 450 U.S. 248 (Supreme Court 1981) (prima facie case and pretext framework in Title VII)
White v. BFI Waste Servs., LLC, 375 F.3d 288 (4th Cir. 2004) (application of McDonnell Douglas framework in the Fourth Circuit)
Mereish v. Walker, 359 F.3d 330 (4th Cir. 2004) (evidence sufficient to show discrimination can be circumstantial)
Price v. Thompson, 380 F.3d 209 (4th Cir. 2004) (prima facie case and retaliation framework)
Lettieri v. Equant Inc., 478 F.3d 640 (4th Cir. 2007) (causation in retaliation claims and temporal proximity considerations)
Mitchell v. Toledo Hosp., 964 F.2d 577 (6th Cir. 1992) (scope of comparators in establishing a prima facie case)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (Supreme Court 1986) (summary judgment standard and material facts)
PBM Prods., LLC v. Mead Johnson Co., 639 F.3d 111 (4th Cir. 2011) (summary judgment standard and de novo review)