Stansberry v. Air Wisconsin Airlines Corp.
651 F.3d 482
| 6th Cir. | 2011Background
- Stansberry managed Air Wisconsin's Kalamazoo operations from 1999 until his firing on July 26, 2007.
- Stansberry's wife has Polyarteritis Nodosa; Air Wisconsin's plan initially covered Remicade for her until May 2007 when coverage was denied.
- Remicade coverage was partially restored through July after an appeal due to timing, creating contemporaneous tension in the workplace.
- Between February and May 2007, six employees under Stansberry received nine security violation letters; Stansberry did not report these to headquarters.
- A TSA investigation was initiated; Mulder, Stansberry's supervisor, was troubled by the lack of reporting.
- Stansberry and his wife filed for Chapter 7 bankruptcy; trustee Meoli later reopened proceedings and joined the suit after right-to-sue letter.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Air Wisconsin discriminated associationally under ADA § 12112(b)(4). | Stansberry argues association with a disabled spouse triggers protection against termination. | Air Wisconsin contends termination for unsatisfactory performance, not association with disability. | Affirmed summary judgment for Air Wisconsin; no prima facie association discrimination shown. |
Key Cases Cited
- Den Hartog v. Wasatch Academy, 129 F.3d 1076 (10th Cir.1997) (establishes four-element framework for associational discrimination under ADA §12112(b)(4))
- Overley v. Covenant Transp., Inc., 178 Fed.Appx. 488 (6th Cir.2006) (adopts McDonnell Douglas framework for association claims)
- Larimer v. International Business Machines Corp., 370 F.3d 698 (7th Cir.2004) (three theories of association discrimination; not exhaustive)
- Erdman v. Nationwide Ins. Co., 582 F.3d 500 (3d Cir.2009) (employer awareness of disability weakens inference of discrimination)
- Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (Supreme Court, 2000) (prima facie case plus evidence of pretext may show discrimination)
- Spengler v. Worthington Cylinders, 615 F.3d 481 (6th Cir.2010) (direct evidence requires inference; not enough to prove discriminatory motive)