Lindeman v. Saint Luke's Hosp. of Kan. City, 899 F.3d 603

Todd Lindeman, employed by St. Luke’s since 2006, suffered from OCD, ADD, bipolar disorder, and physical limitations; his supervisors changed in 2013 to Rosa Parodi and Todd Isbell.
St. Luke’s used a progressive-discipline policy: verbal warning, written warning, suspension/second written warning, then termination for any subsequent infraction.
Between Jan–Apr 2014 Lindeman received: a verbal warning (Jan 1), a written warning (later Jan), a suspension (Feb) and then was terminated (Apr 25) after disclosing a patient’s name in violation of confidentiality rules.
Lindeman sued under the ADA (disability discrimination and failure-to-accommodate) and the ADEA; the district court granted summary judgment for St. Luke’s.
On appeal Lindeman argued the termination was pretext for disability discrimination (and raised a failure-to-accommodate claim); St. Luke’s relied on the confidentiality-policy violation and Lindeman’s disciplinary history.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether termination was pretext for disability discrimination under the ADA	Lindeman: disparate treatment — others disclosed the patient’s name without discipline; prior positive performance followed by rapid discipline shows discriminatory motive	St. Luke’s: termination was for a legitimate nondiscriminatory reason — violation of confidentiality and Lindeman was at terminal stage of progressive discipline	Court: Affirmed summary judgment for St. Luke’s; Lindeman failed to show comparators were similarly situated and his past favorable review does not establish pretext
Whether Lindeman exhausted administrative remedies for a failure-to-accommodate claim under the ADA	Lindeman: (on appeal) argues failure-to-accommodate claim	St. Luke’s: Charge of Discrimination did not include any accommodation request; administrative exhaustion required	Held: Lindeman conceded his EEOC charge contained no accommodation allegation, so he failed to exhaust administrative remedies and cannot pursue that claim in federal court

Torgerson v. City of Rochester, 643 F.3d 1031 (8th Cir. 2011) (summary judgment review standard and drawing inferences for nonmoving party)
EEOC v. Prod. Fabricators, Inc., 763 F.3d 963 (8th Cir. 2014) (McDonnell Douglas framework applied to ADA claims with circumstantial evidence)
McNary v. Schreiber Foods, Inc., 535 F.3d 765 (8th Cir. 2008) (burden-shifting and pretext standard)
Twymon v. Wells Fargo & Co., 462 F.3d 925 (8th Cir. 2006) (violating company policy is a legitimate nondiscriminatory reason for termination)
Forrest v. Kraft Foods, Inc., 285 F.3d 688 (8th Cir. 2002) (requirement that comparators have comparable disciplinary histories)
Liles v. C.S. McCrossan, Inc., 851 F.3d 810 (8th Cir. 2017) (employer’s honest belief in employee misconduct is relevant; plaintiff must show employer didn’t honestly believe violation occurred)
Guimaraes v. SuperValu, Inc., 674 F.3d 962 (8th Cir. 2012) (strong employment history alone cannot establish pretext)