Timothy Andrews v. City of Hartford
700 F. App'x 924
| 11th Cir. | 2017Background
- Plaintiff Timothy Andrews sued the City of Hartford, Alabama alleging employment discrimination under the ADA (among other claims), claiming coworkers harassed him because of his diabetes and that the City failed to accommodate and then fired him despite good performance.
- The district court dismissed Andrews’s complaint for failure to state a claim; Andrews appealed only the dismissal as to his “regarded as” ADA claim.
- Andrews argued the district court applied an outdated pre-ADAAA standard for the “regarded as” prong of ADA disability; the City argued dismissal was proper because Andrews pleaded no facts showing his diabetes motivated the termination.
- The panel reviewed the Rule 12(b)(6) dismissal de novo, applying Twombly/Iqbal pleading standards and ADA statutory definitions post-ADAAA when applicable.
- The court assumed, for argument’s sake, that Andrews could be “regarded as” disabled under the ADAAA and was qualified, but affirmed dismissal because the complaint lacked factual allegations tying the termination to disability (no facts identifying decisionmakers, motives, or that disability was a determinative factor).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court used the correct (post-ADAAA) definition of “regarded as” disabled under the ADA | Andrews: district court applied outdated pre-ADAAA standard; he should be governed by ADAAA’s broader definition | City: even if the court applied wrong definition, Andrews failed to plead facts showing disability-motivated firing | Court: assumed ADAAA definition might apply but affirmed dismissal on alternative ground (insufficient factual allegations tying firing to disability) |
| Whether Andrews pleaded sufficient facts under Twombly/Iqbal to state an ADA "regarded as" discrimination claim | Andrews: alleged harassment for diabetes, failure to accommodate, and termination despite good performance; claimed he was fired because of disability | City: allegations are conclusory; no plausible facts identifying decisionmaker(s), motive, or that disability was a determinative factor | Court: pleadings were conclusory and failed to raise discrimination claim above speculation; dismissal proper |
| Whether plaintiff needed to plead the McDonnell Douglas prima facie elements | Andrews: (implicitly) complaint should survive without detailed prima facie proof | City: dismissal appropriate because complaint lacked facts to allow inference of discrimination | Court: McDonnell Douglas is evidentiary, not pleading standard, but plaintiff still must allege sufficient facts to permit reasonable inference of discrimination under Twombly/Iqbal |
| Whether any procedural defects (waiver/invited error) bar Andrews’s challenge | Andrews: appealed district court’s definition error | City: argued Andrews waived or invited the alleged error | Court: rejected City’s alternative waiver/invited-error argument and affirmed on the pleadings ground |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading must state plausible claim, not mere labels or conclusions)
- Ashcroft v. Iqbal, 556 U.S. 662 (complaint must permit reasonable inference of defendant’s liability; conclusory allegations insufficient)
- Swierkiewicz v. Sorema N.A., 534 U.S. 506 (McDonnell Douglas is an evidentiary, not pleading, standard in discrimination suits)
- Sutton v. United Air Lines, Inc., 527 U.S. 471 (pre-ADAAA standard on being "regarded as" unable to work in a broad class of jobs)
- Farley v. Nationwide Mut. Ins. Co., 197 F.3d 1322 (plaintiff need only show disability was a determinative factor, not sole cause)
- Surtain v. Hamlin Terrace Foundation, 789 F.3d 1239 (elements of an ADA "regarded as" claim)
- Mazzeo v. Color Resolutions Intern., LLC, 746 F.3d 1264 (post-ADAAA definitions apply when critical events occur after ADAAA)
- Leib v. Hillsborough Cnty. Pub. Transp. Comm’n, 558 F.3d 1301 (standard of review for Rule 12(b)(6) dismissal)