Magnus v. St. Mark United Methodist Church
688 F.3d 331
7th Cir.2012Background
- Magnus sued St. Mark United Methodist Church for associational discrimination under the ADA based on her association with a disabled daughter; the church won summary judgment.
- Magnus previously worked part-time 2006–2008, then became a full-time salaried secretary in 2008 with a Monday–Friday schedule but was asked to work weekends.
- Magnus refused weekend work because she took her daughter home on weekends and could not arrange care; the church proposed alternative weekend schedules.
- In November 2008 the church documented deficiencies in Magnus’s performance and counseled her; shortly after, she received a five percent across-the-board raise in January 2009 with no formal performance evaluation.
- Magnus was terminated in January 2009, the church citing ongoing poor performance and her refusal to work weekends; the district court and court below upheld summary judgment for the church, rejecting associational-discrimination liability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Magnus’s ADA associational-discrimination claim survives. | Magnus argues termination was due to association with a disabled daughter. | Church maintained a legitimate performance-based rationale; no discriminatory motive shown. | No; church reasons were legitimate and no causal link shown. |
| Whether temporal proximity supports causation. | Termination occurred shortly after late arrival due to daughter's care. | Timing alone is insufficient without other supporting evidence. | No; termination decision occurred before the late arrival and lacks supporting evidence of discriminatory intent. |
| Whether employer must accommodate schedule to care for a disabled relative. | Church should have accommodated Magnus’s weekend-care needs. | ADA does not require accommodation for non-disabled employees or modify schedules for care of disabled relatives. | No; employer not obligated to provide such accommodation. |
Key Cases Cited
- Larimer v. International Business Machines Corp., 370 F.3d 698 (7th Cir. 2004) (association discrimination framework; three categories including distraction)
- Dewitt v. Proctor Hospital, 517 F.3d 944 (7th Cir. 2008) (concurring discussion on association-discrimination)
- Tyndall v. National Educational Center, 31 F.3d 209 (4th Cir. 1994) (no accommodation required for non-disabled employee)
- Erdman v. Nationwide Insurance Co., 582 F.3d 500 (3d Cir. 2009) (employer cannot terminate on unfounded assumptions about care needs; accommodation not required for non-disabled)
- Stockwell v. City of Harvey, 597 F.3d 895 (7th Cir. 2010) (discrimination analysis; determining factor requires inference of discriminatory intent)
- Koski v. Standex International Corp., 307 F.3d 672 (7th Cir. 2002) (association-discrimination analysis; timing and motives)
- O’Regan v. Arbitration Forums, Inc., 246 F.3d 975 (7th Cir. 2001) (not a super-personnel review of decisions; deference to employer)
- Davis v. Time Warner Cable of Southeast Wisconsin, L.P., 651 F.3d 664 (7th Cir. 2011) (temporal proximity as evidence of causation requires context)