Summary Judgment Win on Disability and Age Discrimination Claims Against a Medical-Practice Client

Following the recommendation of a Magistrate Judge, a federal court recently granted our Motion for Summary Judgment and dismissed numerous discrimination claims brought by an employee of one of our clients under the Americans with Disabilities Act (“ADA), the Age Discrimination in Employment Act (“ADEA”) and Title VII of the Civil Rights Act (“Title VII”).

Plaintiff first alleged age, race, and gender discrimination when he was passed over for a promotion in favor of a younger colleague, even though the chosen candidate shared the same race and gender as Plaintiff. We argued that there was no evidence supporting the claims that age was a decisive factor in the decision, and that our client had a legitimate, non-discriminatory reason for choosing the other candidate for the promotion, including his superior experience and positive evaluations. The court recognized the evidence in our client’s favor and dismissed all three claims.

Plaintiff next claimed he had been subjected to disparate treatment during a number of situations based on his gender, race, age, and supposed disability. However, the court meticulously dissected the evidence, which included deposition testimony from Plaintiff, and found the claims to be mere inconveniences that didn’t rise to the level of materially adverse employment actions. With this core element missing, Plaintiff’s disparate treatment claims crumbled and were likewise dismissed.

Plaintiff’s final allegation was that our client failed to provide reasonable accommodations for his supposed disability. While the court recognized that he did have an established condition, Plaintiff admitted through his own testimony that he could perform his job duties effectively without needing any accommodations. As such, the court determined that his condition could not be defined as a protected disability under the ADA, and therefore, our client was not held to the ADA standards to provide accommodations.

With all federal claims dismissed, the court declined jurisdiction over Plaintiff’s remaining state-level claims, allowing them to be dismissed without prejudice. We are very proud to have protected our client from further litigation on these frivolous claims that they discriminated against their employee. This case highlights the need in discrimination cases for concrete evidence showing substantial harm. Mere grievances and inconveniences are insufficient to meet the legal burden of proof.