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Muzyka v. Regions Bank
8:10-cv-02413
M.D. Fla.
Jan 25, 2012
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Background

  • 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)
Read the full case

Case Details

Case Name: Muzyka v. Regions Bank
Court Name: District Court, M.D. Florida
Date Published: Jan 25, 2012
Docket Number: 8:10-cv-02413
Court Abbreviation: M.D. Fla.