106 F.4th 101
1st Cir.2024Background
- William Rios, a part-time security guard with diabetes, worked for Centerra Group, LLC providing security at U.S. Coast Guard facilities in Puerto Rico.
- Rios was terminated after being found asleep at his post, which was grounds for termination under company policy.
- Rios claimed his sleeping incident was caused by a hypoglycemic episode and asserted Centerra knew or should have accommodated his disability.
- Rios sued Centerra for violations under the Americans with Disabilities Act (ADA), alleging discrimination, failure to accommodate, hostile work environment, and retaliation; the district court granted summary judgment to Centerra on all claims.
- On appeal, Rios challenged the summary judgment and the district court’s denial of extra discovery under Rule 56(d).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held (Court Ruling) |
|---|---|---|---|
| ADA Discrimination | Firing was due to Rios's disability; comparators treated better | Termination was for sleeping on duty | Affirmed summary judgment for Centerra; no evidence of pretext |
| Failure to Provide Accommodation | Centerra failed to engage in interactive process | Rios never made a specific accommodation request | No failure by Centerra; Rios stalled process and provided no medical info |
| Hostile Work Environment (ADA) | Supervisor harassed Rios due to his disability | Supervisor's actions unrelated to disability; incidents before knowledge of diabetes | No objectively hostile environment; no evidence of disability-based animus |
| Retaliation under ADA | Firing was due to grievances and protected activity | Fired for sleeping, not in retaliation | No evidence of pretext or causation; proximity alone insufficient |
| Denial of Rule 56(d) discovery | Needed more time to obtain comparator evidence | Delay unjustified; ample discovery time | No abuse of discretion; motion untimely and unsupported |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes burden-shifting framework for discrimination claims)
- Murray v. Warren Pumps, LLC, 821 F.3d 77 (ADA discrimination and hostile work environment standards)
- Brader v. Biogen Inc., 983 F.3d 39 (pretext and summary judgment burden in discrimination cases)
- Kosereis v. Rhode Island, 331 F.3d 207 (comparator analysis in discrimination claims)
- Morales-Vallellanes v. Potter, 605 F.3d 27 (definition of adverse employment action)
- Cherkaoui v. City of Quincy, 877 F.3d 14 (temporal proximity in retaliation claims)
- Bhatti v. Trustees of Boston Univ., 659 F.3d 64 (reprimands as adverse actions in discrimination/retaliation)