Julie Barlia v. MWI Veterinary Supply, 17-1185

Background

Barlia was an outside sales representative for MWI from 2008 until her termination on June 3, 2014; she repeatedly missed 95% sales targets in 2013–2014 and was placed on a PIP on May 9, 2014.
In January 2014 Barlia requested an accommodation (excusal from a national sales meeting) for medical reasons; she provided a note from her endocrinologist describing symptoms consistent with thyroid/hormonal imbalance and advising against travel.
MWI began considering company-wide expense reductions in May 2014 and selected employees for potential layoff; Walsh (regional manager) nominated Barlia because she was on a PIP, had long-term poor sales, and was disengaged in non-sales communication.
Barlia filed suit under the ADA, alleging (1) disability discrimination (actual disability and/or regarded-as) and (2) retaliation for requesting accommodation.
The district court granted summary judgment for MWI, finding Barlia failed to show she was disabled under the ADA, failed to show pretext for MWI’s legitimate non-discriminatory reasons, and failed to show causation for her retaliation claim.
The Sixth Circuit affirmed: it held a genuine dispute existed as to whether Barlia had hypothyroidism sufficient to be an ADA impairment, but she failed to show MWI’s stated reason for termination was pretextual and failed to prove but-for causation for retaliation.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Barlia was "disabled" under the ADA (actual disability)	Hypothyroidism and related conditions (symptoms, synthroid prescription, physician notes) substantially limited major life activities (concentrating, thinking; endocrine function)	Medical records do not show a formal diagnosis or substantial limitation	Court: Genuine dispute on actual disability — reasonable jury could find hypothyroidism constituted an ADA impairment
Whether MWI’s stated reason for termination was pretextual	PIP timing and comparisons to non-disabled OSRs show PIP was cover for discrimination; coworkers with worse sales were treated better	PIP preceded knowledge of workforce reduction; termination was part of workforce reduction and based on performance (sales + communication/engagement); employer had honest belief in its facts	Court: No genuine dispute of pretext — employer honestly relied on particularized facts (performance and engagement); plaintiff failed to rebut with probative evidence
Whether plaintiff established prima facie disability discrimination (including employer knowledge / singled out)	Employer knew of medical note excusing travel; termination selected her despite accommodation request	Employer selected based on PIP and relative performance/engagement; workforce reduction process legitimate	Court: Declined to decide all prima facie elements because pretext failure was dispositive; summary judgment affirmed on discrimination claim
Whether there was unlawful retaliation for requesting accommodation	Requesting accommodation (NSM excusal) was protected activity; subsequent denial of ride-with, PIP, discharge were adverse actions causally connected	Temporal gap (3–4 months) and legitimate non-discriminatory reasons break causal chain; plaintiff must show but-for causation	Court: Retaliation claim fails — temporal proximity alone insufficient given elapsed time; no additional evidence of causation; but-for causation not shown

Key Cases Cited

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes burden-shifting framework for disparate treatment claims)
St. Mary’s Honor Center v. Hicks, 509 U.S. 502 (plaintiff must show employer's proffered reason is pretext and that discrimination was real reason)
Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden rules)
Anderson v. Liberty Lobby, 477 U.S. 242 (standard for genuine dispute and significant probative evidence)
Chen v. Dow Chem. Co., 580 F.3d 394 (6th Cir. review standards for summary judgment)
Whitfield v. Tennessee, 639 F.3d 253 (prima facie elements for ADA discrimination)
Majewski v. Automatic Data Processing, 274 F.3d 1106 (honest-belief rule for employer decisions)
Tingle v. Arbors at Hilliard, 692 F.3d 523 (employer entitled to summary judgment when it reasonably and honestly relies on particularized facts)
Ferrari v. Ford Motor Co., 826 F.3d 885 (pretext standards and ways to show pretext)
Rorrer v. City of Stow, 743 F.3d 1025 (ADA retaliation prima facie elements and causation)
Lewis v. Humboldt Acquisition Corp., 681 F.3d 312 (but-for causation requirement for ADA retaliation)