Smith v. Haynes Incorporated
2:17-cv-03446-BHH
| D.S.C. | Jun 27, 2019Background
- Plaintiff Jessica Smith sued Haynes Inc. under the ADA alleging failure to accommodate, disability discrimination (including wrongful discharge), hostile work environment, and retaliation.
- Defendant moved for summary judgment; Magistrate Judge Shiva V. Hodges issued a Report recommending summary judgment for Defendant.
- Smith filed objections to the Magistrate Judge’s Report; objections largely repeated arguments from her summary judgment response.
- District Judge Bruce H. Hendricks reviewed the Report and Smith’s objections under 28 U.S.C. § 636(b) and local rules.
- The Court found Smith’s objections insufficiently specific and that she failed to identify any overlooked facts creating a genuine dispute of material fact on any ADA claim.
- The Court adopted the Magistrate Judge’s Report in full, overruled Smith’s objections, and granted Haynes’s motion for summary judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Adequacy and specificity of objections to Magistrate Judge’s Report | Smith argued the Report failed to view facts in her favor and raised factual/legal disputes. | Haynes argued objections merely rehashed prior briefing and lacked the required specificity to trigger de novo review. | Court held objections were nonspecific, largely recycled prior arguments, and did not identify errors warranting de novo review. |
| Failure-to-accommodate under ADA | Smith contended Haynes failed to provide reasonable accommodations for her disability. | Haynes argued Smith did not present facts creating a triable issue that a reasonable accommodation was available and denied. | Court adopted Magistrate Judge: no genuine issue of material fact; summary judgment for Haynes. |
| Disability discrimination / wrongful discharge | Smith claimed adverse employment actions were due to disability. | Haynes maintained legitimate, non-discriminatory reasons for actions and no evidence of discriminatory motive. | Court held Smith failed to produce facts showing discrimination or pretext; summary judgment for Haynes. |
| Retaliation and hostile work environment | Smith alleged she was retaliated against for protected activity and subjected to a hostile workplace due to disability. | Haynes argued no causal link or severe/pervasive conduct creating hostile environment; no triable issues. | Court agreed there was insufficient evidence of causation or hostile-environment elements; summary judgment for Haynes. |
Key Cases Cited
- Veney v. Astrue, 539 F. Supp. 2d 841 (W.D. Va. 2008) (objections that merely restate prior briefing are insufficiently specific to trigger de novo review)
- United States v. Midgette, 478 F.3d 616 (4th Cir. 2007) (party must object with sufficient specificity to reasonably alert the district court to the true ground for the objection)