Minter v. District of Columbia
809 F.3d 66
D.C. Cir.2015Background
- Minter, disabled by sarcoidosis and sarcoid arthritis, sought a reduced schedule as an ADA accommodation.
- In September 2006, she injured herself on a waxed floor, worsening her condition.
- ADA Coordinator Williams engaged in an interactive process; December 1, 2006 meeting did not finalize an accommodation.
- From February to May 2007 Minter missed work; OCME requested documentation; she provided a June 19, 2007 physician certificate stating total disability and indefinite absence.
- OCME terminated Minter in June 2007 due to sustained absence and lack of documentation; she sued under the ADA and Rehabilitation Act.
- District court granted summary judgment; this court affirms, holding she was not a qualified individual and there was no retaliatory motive.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district failed to accommodate | Minter contends the District refused accommodation for disability. | District asserts it engaged in interactive process and did not deny accommodation. | No denial; interactive process ongoing; no accommodation denial established. |
| Whether Minter was a qualified individual | Minter argues she could perform functions with accommodation. | As of June 1, 2007 she was not performing work and was continuously disabled. | Minter not qualified as of denial; unable to perform essential functions. |
| Whether termination was retaliation for accommodation request | Termination cited proximity to accommodation request as retaliation. | Termination due to abandonment and lack of reporting/ documentation; legitimate reason. | No causal link; legitimate nondiscriminatory reason supported. |
| Whether inconsistent rationale creates triable issue | Fields' deposition suggested a different reason than litigation. | Any inconsistency does not prove pretext; not enough to show retaliatory motive. | Insufficient evidence of pretext; summary judgment affirmed. |
Key Cases Cited
- Solomon v. Vilsack, 763 F.3d 1 (D.C. Cir. 2014) (establishes framework for reasonable accommodation and qualified individual)
- Ward v. McDonald, 762 F.3d 24 (D.C. Cir. 2014) (interactive process and denials require evidence of bad faith or end)
- Stewart v. St. Elizabeths Hosp., 589 F.3d 1305 (D.C. Cir. 2010) (interactive process and accommodation standards under ADA/RA)
- Adeyemi v. District of Columbia, 525 F.3d 1222 (D.C. Cir. 2008) (pretext analysis requires more than proximity to establishment of retaliation)
- Doak v. Johnson, 798 F.3d 1096 (D.C. Cir. 2015) (retaliation claim requires showing actual motive beyond timing)
- Mogenhan v. Napolitano, 613 F.3d 1162 (D.C. Cir. 2010) (timeframe for qualification and performance in ADA analysis)
- Flemmings v. Howard Univ., 198 F.3d 857 (D.C. Cir. 1999) (focus on whether employee could perform essential functions with/without accommodation)