Muzyka v. Regions Bank
8:10-cv-02413
M.D. Fla.Jan 25, 2012Background
- Muzyka has bipolar disorder for about 20 years and takes multiple medications.
- Regions Bank hired Muzyka in June 2008 as a Personal Banker with sales/activity goals and specific performance metrics.
- Muzyka sought accommodations in 2009 (collegial management, 24–48 hour deadline flexibility, reduced workload); some requests were partially accommodated (remote access, assistant input) while others were rejected.
- Muzyka was disciplined for underperforming on Wealth Assessment Model (WAM) goals, receiving a verbal corrective action and a final written warning in 2009.
- Muzyka was terminated on December 11, 2009 after the disciplinary steps and subsequently filed a charge of discrimination (November 11, 2009).
- There is a factual dispute over Muzyka’s performance data (scorecards) and whether the termination was motivated by disability rather than performance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Muzyka is a qualified individual. | Muzyka met or exceeded goals per scorecards and was eligible for bonuses. | Muzyka failed to meet essential job functions; performance metrics show consistent underperformance. | Genuine issue of material fact; not resolved at summary judgment. |
| Whether Regions Bank terminated Muzyka for discriminatory reasons related to disability. | Termination was pretextual given conflicting performance evidence and disability status. | Termination was based on unmet performance standards and not on disability. | Genuine issue of material fact; jury should resolve pretext. |
| Whether Muzyka engaged in protected activity and whether there is a causal link to termination. | Muzyka’s ADA accommodations request and discrimination charge constitute protected activity leading to termination. | Termination causally related to performance deficiencies; no evidence tying termination to protected activity. | Issue for jury to determine causation. |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (establishes burden-shifting framework for discrimination claims)
- Davis v. Florida Power & Light Co., 205 F.3d 1301 (11th Cir. 2000) (definition of qualified individual and essential functions framework)
- Jackson v. Alabama State Tenure Comm’n, 405 F.3d 1276 (11th Cir. 2005) (pretext and credibility considerations in discrimination claims)
- Meeks v. Computer Associates Int’l, 15 F.3d 1013 (11th Cir. 1994) (causal link and burden-shifting for retaliation claims)
- Uviedo v. Steves Sash & Door Co., 738 F.2d 1425 (5th Cir. 1984) (court may not resolve credibility issues at summary judgment)
- Increase Minority Participation by Affirmative Change Today, Inc. v. Firestone, 893 F.2d 1189 (5th Cir. 1990) (evidence required to support employer’s reasons for discharge)
- Pennington v. City of Huntsville, 261 F.3d 1262 (11th Cir. 2001) (causation and protected activity nexus in retaliation cases)
- Holly v. Clairson Indus., LLC, 492 F.3d 1247 (11th Cir. 2007) (analysis framework for ADA discrimination claims)
- Alexander v. Fulton Cty., Ga., 207 F.3d 1303 (11th Cir. 2000) (case-by-case determination of essential functions)
