Lewis v. Humboldt Acquisition Corp., Inc.
634 F.3d 879
| 6th Cir. | 2011Background
- Susan Lewis, a registered nurse, began work at Humboldt Manor Nursing Home in July 2004.
- Around September 2005 she developed a disability affecting her lower extremities and sometimes used a wheelchair.
- She was terminated on March 20, 2006, allegedly for an outburst at the nurses' station on March 15.
- Lewis claimed the true reason was her disability and that the facility used the outburst as pretext.
- The district court instructed the jury under the Monette 'solely' standard for ADA discrimination, and the jury found in Lewis's favor on two elements but not that disability was the sole reason.
- The panel affirmed the district court, holding it cannot overrule Monette and the Monette standard remains controlling in the Sixth Circuit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a panel may overrule Monette’s sole-reason standard | Lewis seeks to overrule Monette. | Monette binding on panel; en banc review required to overruling. | Panel cannot overrule Monette; Monette remains binding. |
| Whether the ADA requires 'solely' or 'motivating factor' causation | Disability only needs to be a motivating factor. | ADA requires disability to be the sole reason for termination. | The panel affirms Monette; sole-causation standard applies in this circuit. |
Key Cases Cited
- Monette v. Elec. Data Sys. Corp., 90 F.3d 1173 (6th Cir.1996) (discrimination plaintiff must show sole cause due to handicap in this circuit)
- Salmi v. Sec'y of Health & Human Servs., 774 F.2d 685 (6th Cir.1985) (reported panel opinions binding on subsequent panels; en banc required to overrule)
- Macy v. Hopkins County Sch. Bd. of Educ., 484 F.3d 357 (6th Cir.2007) (panel bound by Monette; cannot overturn panel decisions on this issue)
- Hedrick v. W. Reserve Care Sys., 355 F.3d 444 (6th Cir.2004) (requires Monette-like standard in ADA claims (binding precedent))
- Jones v. Potter, 488 F.3d 397 (6th Cir.2007) (reinforces Sixth Circuit adoption of sole-reason standard)
- Monette v. Elec. Data Sys. Corp., 90 F.3d 1173 (6th Cir.1996) (foundation for 'solely' standard in ADA claims)