Lewis v. Humboldt Acquisition Corp., Inc.
681 F.3d 312
| 6th Cir. | 2012Background
- Susan Lewis, a registered nurse, was terminated by Humboldt in March 2006 after an alleged work outburst.
- Lewis sued under the ADA claiming she was discriminated against because of her disability (walking impairment/wheelchair use).
- The district court instructed the jury that liability required sole cause by disability, adopting Humboldt's proposed instruction.
- The jury found in Humboldt's favor; Lewis sought a new trial arguing the instruction misapplied the ADA’s causation standard.
- The Sixth Circuit en banc reversed the judgment, holding that the ADA does not require a sole-cause standard and that importing the Rehabilitation Act or Title VII standards into the ADA is inappropriate.
- The court remanded for a new trial with proper ADA causation guidance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| What causation standard governs the ADA claim? | Lewis argues ADA uses motivating-factor standard. | Humboldt argues ADA requires sole-cause standard. | ADA uses a causation standard not limited to sole-cause; but-for standard applies under Gross framework |
| Should ADA import Title VII's motivating-factor framework via § 12117 or cross-references? | Lewis contends cross-referenced enforcement provisions bring motivating-factor standard into ADA. | Humboldt contends cross-reference does not alter ADA causation; avoid importing Title VII’s standard. | Cannot import motivating-factor framework from Title VII into the ADA |
| Does the ADA's incorporation of Title VII remedies affect causation standard or only remedies? | Plaintiff argues remedies under Title VII force a motivating-factor standard in ADA actions. | Defendant argues incorporation does not change ADA's causation standard. | Remedies context does not override ADA's causation standard; but-for applies |
| What should the trial court instruct on causation for ADA claims on remand? | Plaintiff seeks instructions consistent with motivating-factor approach. | Defendant favors but-for approach with potential same-decision defense for remedies. | Proceed with but-for causation framework consistent with Gross |
Key Cases Cited
- Gross v. FBL Financial Services, Inc., 557 U.S. 167 (U.S. 2009) (but-for causation; limited or no mixed-motive relief in ADEA context)
- Price Waterhouse v. Hopkins, 490 U.S. 228 (U.S. 1989) (mixed-motive framework; motivating-factor concept)
- Serwatka v. Rockwell Automation, Inc., 591 F.3d 957 (7th Cir. 2010) (ADA mixed-motive debate; applied but-for view in some circuits)
- Smith v. Xerox Corp., 602 F.3d 320 (5th Cir. 2010) (compares Gross and Serwatka; cautions against broad Gross application)
- Head v. Glacier Northwest, Inc., 413 F.3d 1053 (9th Cir. 2005) (advocates motivating-factor under plain-language interpretation)
- Monette v. Electronic Systems Corp., 90 F.3d 1173 (6th Cir. 1996) (early sixth-circuit ADA standard discussion)
- Maddox v. University of Tennessee, 62 F.3d 843 (6th Cir. 1995) (origin of sole-cause doctrine in ADA/Rehabilitation Act context)