Southeast ADA Center
2011
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In July 2004, the Plaintiff, Susan Lewis, started working at Humboldt Manor Nursing Home (“Humboldt Manor.”) In September 2005, she developed a medical condition which made it difficult for her to walk and required her to use a wheelchair at times. The medical condition also prevented her from working for one month.
On March 20, 2006, Humboldt Manor terminated Ms. Lewis, allegedly because of an “outburst,” which, according to testimony by three employees, consisted of yelling profanely and criticizing Ms. Lewis’ employers. Another employee contradicted this account, testifying that Ms. Lewis was upset but did not act in an inappropriate manner. Ms. Lewis contended that the reason for her termination was her disability, and specifically the use of her wheelchair, and that Humboldt Manner exaggerated the incident as a pretext for her termination.
Ms. Lewis filed suit in federal court, alleging wrongful termination under the ADA. She argued that, in order to show employment discrimination under the ADA, it was only necessary for her to demonstrate that her disability was one “motivating factor” in her employer’s decision to fire her. However, the District Court instructed the jury that it was not enough to show that the plaintiff’s disability was merely a contributing factor to the employer’s firing decision. Instead, the Court stated that the plaintiff must demonstrate that her disability was the “sole reason” for the employer’s decision to terminate her employment.
The jury found that Ms. Lewis’ disability was not the sole reason for her termination, primarily because her alleged “outburst” constituted an additional reason, and therefore determined that her ADA claim should fail. Ms. Lewis then appealed to the Sixth Circuit Court of Appeals, arguing that the District Court’s “solely on the basis of disability” jury instruction was erroneous.
https://adasoutheast.org/court-decisions/lewis-v-humboldt-acquisition-corp-inc
Keywords: discrimination, employment, legal concepts, sole causation