Martin v. University of Tennessee, 3:24-cv-00075

Dr. Kelly Brooke Martin, proceeding pro se, sued the University of Tennessee alleging employment discrimination based on her disability, age, and genetic information.
Plaintiff alleged discrimination, harassment, failure to accommodate, and retaliation related to her termination, citing the Genetic Information Nondiscrimination Act (GINA), Americans with Disabilities Act (ADA), and Age Discrimination in Employment Act (ADEA).
The University filed a motion for partial summary judgment, arguing Plaintiff's claims fail as a matter of law, regardless of any factual disputes.
Key allegations revolved around Plaintiff’s medical condition (Spondyloepiphyseal Dysplasia Congenita) and her employer’s knowledge and requests for medical documentation.
The University asserted that Plaintiff’s ADA and ADEA claims were barred by sovereign immunity, and her GINA claim did not legally apply to her alleged facts.
The court considered only Plaintiff’s remaining claims under GINA, ADA, and ADEA, as previous claims had already been dismissed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Plaintiff’s medical condition is	Defendant discriminated and retaliated against her due to her genetic	Plaintiff’s medical condition is not “genetic information” under GINA; no actionable conduct.	GINA does not apply; claim fails as matter of law.
actionable under GINA	disorder, and unlawfully requested her medical and disability records.
Whether ADA claim survives Eleventh Amendment	ADA claim falls under Title II (where sovereign immunity is abrogated)	ADA claim properly arises under Title I; Eleventh Amendment bars suit for state employment acts.	Sovereign immunity bars the ADA claim.
Whether ADEA claim survives Eleventh Amendment	Not expressly argued, but seeks monetary and possibly equitable relief	ADEA claims for monetary/equitable relief against state entity barred by sovereign immunity.	Sovereign immunity bars the ADEA claim.
Whether Ex parte Young permits equitable/	Ex parte Young exception allows injunctive/equitable relief to proceed	Exception only applies to suits against state officials, not the state or its agencies.	Ex parte Young does not apply against the University.
injunctive relief against the University

Kimel v. Fla. Bd. of Regents, 528 U.S. 62 (Sovereign immunity bars ADEA claims for monetary damages against state entities)
Bd. of Trs. of Univ. of Ala. v. Garrett, 531 U.S. 356 (ADA Title I claims barred by the Eleventh Amendment)
Tennessee v. Lane, 541 U.S. 509 (Title II of ADA abrogates Eleventh Amendment immunity in specific contexts)
Ex parte Young, 209 U.S. 123 (Exception to Eleventh Amendment for certain suits against state officials)
Williams v. Graphic Packaging Int’l, Inc., 790 F. App’x 745 (GINA applies only to genetic information, not manifested conditions)