Valtierra v. Medtronic Inc., 232 F. Supp. 3d 1117

Valtierra worked for Medtronic as a Facilities Maintenance Technician (hired 2004) performing physically demanding tasks; he is morbidly obese and took FMLA leave Aug–Dec 2013 for weight-related knee/joint pain.
After returning from FMLA leave, he remained in the same position, pay, and shift; Matrix processed his FMLA paperwork.
On June 11, 2014, Valtierra logged 12 preventive maintenance (PM) tasks as completed in the company system just before vacation; supervisor Duke investigated and discovered the work had not been performed.
Valtierra admitted signing off on the 12 PMs without doing the work; he was placed on administrative leave and discharged on July 2, 2014, for falsification of company records.
Valtierra sued for (1) FMLA interference, (2) disability discrimination under the ADA (actual and regarded-as disability), and (3) ADA retaliation for requesting accommodations; Medtronic moved for summary judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
ADA — actual disability (Count 2)	Morbid obesity is a disability (clinically diagnosed) that limits major life activities.	Obesity alone is a physical characteristic, not a "physiological" impairment under ADA regs; no evidence obesity resulted from a physiological disorder.	Court: Morbid obesity, standing alone, is not an ADA disability here; no evidence of underlying physiological disorder.
ADA — regarded-as disability (Count 2)	Medtronic perceived him as limited (difficulty walking, used motorized cart), so he is protected.	Employer did not regard him as having an ADA-defined physiological impairment.	Court: No evidence Medtronic regarded him as having an ADA "impairment;" regarded-as claim fails.
ADA — retaliation (Count 3)	Duke assigned tasks implicating stairs/ladders after accommodation requests; termination was retaliatory (temporal proximity ~6 months).	Termination resulted from admitted falsification/misconduct; not "but-for" retaliation.	Court: No genuine dispute — misconduct was the but-for cause of discharge; summary judgment for Medtronic.
FMLA — interference (Count 1)	Employer used prior FMLA leave and anticipated surgery as a basis to interfere/retaliate.	Valtierra took approved FMLA in 2013; he did not request additional FMLA before discharge; termination was for misconduct.	Court: No triable issue — no evidence FMLA leave was a negative factor in the 2014 discharge; summary judgment for Medtronic.

Morriss v. BNSF Ry. Co., 817 F.3d 1104 (8th Cir. 2016) (weight is a physical characteristic that qualifies as an impairment only if caused by an underlying physiological disorder)
EEOC v. Watkins Motor Lines, Inc., 463 F.3d 436 (6th Cir. 2006) (obesity must result from a physiological condition to be an ADA impairment)
Francis v. City of Meriden, 129 F.3d 281 (2d Cir. 1997) (obesity, except in special cases, is not a physical impairment; limits on expanding regarded-as prong)
Univ. of Tex. Southwestern Med. Ctr. v. Nassar, 133 S. Ct. 2517 (2013) (retaliation requires but-for causation)
Bachelder v. Am. W. Airlines, Inc., 259 F.3d 1112 (9th Cir. 2001) (employers may not use FMLA leave as a negative factor in employment decisions)
Xin Liu v. Amway Corp., 347 F.3d 1125 (9th Cir. 2003) (FMLA interference requires evidence employer considered FMLA in adverse action)
Fleming v. IASIS Healthcare Corp., 151 F. Supp. 3d 1043 (D. Ariz. 2015) (employee who requested FMLA may still be discharged for independent misconduct)
Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard and burden shifting)
Anderson v. Liberty Lobby, 477 U.S. 242 (summary judgment—genuine dispute and materiality standards)