Marissa Walz v. Ameriprise Financial, Inc.
779 F.3d 842
| 8th Cir. | 2015Background
- Walz worked for Ameriprise from 1996 to 2012 as a Process Analyst and was recruited for strong interpersonal skills.
- Walz has bipolar disorder; coworkers and supervisor reported disruptive, erratic, and rude behavior beginning March 2012.
- After escalating incidents and a formal behavior warning, Walz took FMLA leave via Ameriprise’s vendor; she returned with a doctor’s note limiting to 40 hours/week and noting stabilization on medication.
- Walz reviewed Ameriprise’s treatment policy; she did not disclose bipolar disorder or request an accommodation at any point.
- Walz was terminated in July 2012 for repeated misconduct; she sued under the ADA and MHRA alleging wrongful termination and failure to accommodate.
- The district court granted summary judgment for Ameriprise, concluding Walz failed to show she was a qualified individual or that a failure to accommodate occurred.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Walz was a qualified individual under the ADA | Walz could perform essential functions with accommodations | Walz failed to show she could perform essential functions with/without accommodation | Walz failed to show qualification; summary judgment affirmed on this basis |
| Whether Walz’s termination was based on disability | Termination due to bipolar disorder | Disciplinary misconduct rather than disability | Court affirmed based on lack of genuine issue on qualification; alternative basis sufficient |
| Whether Ameriprise had a duty to accommodate given Walz’s non-obvious disability | Employer should have accommodated Walz | No disclosure of disability or request for accommodation; no duty arises | No duty to accommodate absent notice or request; summary judgment upheld |
| Whether Walz’s freestanding failure-to-accommodate claim survives without a request for accommodation | Employer should have forced leave as accommodation | No request for accommodation = no liability | Claim fails for lack of an accommodation request |
Key Cases Cited
- Wal-Mart Stores, Inc. v. Blayne, 477 F.3d 561 (8th Cir. 2007) (ADA analysis includes essential-function framework)
- Kallail v. Alliant Energy Corporate Servs., Inc., 691 F.3d 925 (8th Cir. 2012) (prima facie case requires disability, qualification, and causal link)
- Rask v. Fresenius Med. Care N. Am., 509 F.3d 466 (8th Cir. 2007) (may show qualified with accommodation; reminder of non-obvious disabilities)
- Saulsberry v. St. Mary’s Univ. of Minn., 318 F.3d 862 (8th Cir. 2003) (courts may affirm on alternative grounds if supported by record)
- Ballard v. Rubin, 284 F.3d 957 (8th Cir. 2002) (no duty to accommodate absent an employee request)
- Torgerson v. City of Rochester, 643 F.3d 1031 (8th Cir. 2011) (movant bears initial duty to inform district court of motion bases)
- Celotex Corp. v. Catrett, 477 U.S. 317 (Supreme Court 1986) (summary judgment standard; burden on moving party to show no genuine issue)
- Wal-Mart Stores, Inc. v. Dukes, 477 F.3d 561 (8th Cir. 2007) (ADA/essential functions analysis and burden-shifting principles)