Ramos-Echevarria v. Pichis, Inc.
659 F.3d 182
| 1st Cir. | 2011Background
- Ramos-Echevarría has epilepsy and uses medication; he experiences frequent episodes with aura but does not lose consciousness.
- He works part-time as a kitchen assistant for Pichis and has a second job at Palacio Chino; his illness has generally not affected performance.
- Early in employment, he was told by the owner he could not continue due to his condition, and he requested a reasonable accommodation.
- He was rehired after providing a doctor’s certificate stating his condition did not prevent work, though certain activities may be restricted.
- He claims he was denied full-time hours and that others hired after him received more hours; Pichis cites slow business as the reason for not increasing hours.
- District court granted summary judgment to Pichis on ADA claims; Ramos-Echevarría’s federal claims were then supplemented by Puerto Rico law claims, which were dismissed without prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Ramos-Echevarría has a disability under the ADA | Ramos-Echevarría has epilepsy that substantially limits work | Epilepsy does not substantially limit a major life activity | Not established as a disability under the ADA |
| Whether epilepsy substantially limits the major life activity of working | Epilepsy substantially limits his ability to work | No substantial limitation; can work with limitations | Not substantially limiting; fails the ADA standard |
| Whether Ramos-Echevarría has a 'record of impairment' under the ADA | Medical records show treatment history demonstrating a record | Records do not show substantial impairment history | Not a record of impairment that substantially limits a major life activity |
| Whether the district court abused its discretion in dismissing supplemental state-law claims | Federal claim failing should not affect state claims | Abstention and dismissal without prejudice appropriate | No abuse of discretion; affirmed supplemental dismissal |
Key Cases Cited
- Bragdon v. Abbott, 524 U.S. 624 (Sup. Ct. 1998) (defined disability under ADA and three-part analysis)
- Carroll v. Xerox Corp., 294 F.3d 231 (1st Cir. 2002) (three-step impairment analysis for disability)
- Toyota Motor Mfg., Ky., Inc. v. Williams, 534 U.S. 184 (Sup. Ct. 2002) (limits must be permanent/long-term; not mere episodic impairment)
- Sutton v. United Air Lines, 527 U.S. 471 (Sup. Ct. 1999) (defining substantial limitation; class-wide vs. single job)
- Albertson’s, Inc. v. Kirkingburg, 527 U.S. 555 (Sup. Ct. 1999) (substantial limitation evidence must be individualized)
- Doebele v. Sprint/United Mgmt. Co., 342 F.3d 1117 (10th Cir. 2003) (record-of-impairment analysis applied to ADA)
- Freadman v. Metro. Prop. & Cas. Ins. Co., 484 F.3d 91 (1st Cir. 2007) (burden shifting in ADA discrimination)