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Morgan v. Hilti, Inc.
No. 96-5111 (10th Cir. Mar. 18, 1997) ; Clearinghouse Number: 52213
Description
District Court Applied Improper Legal Standard in Disability Discrimination Action
Abstract
The Tenth Circuit has affirmed the district court’s order
granting defendant employer summary judgment in this employment
discrimination action. Plaintiff employee alleged that defendant
discriminated against her in violation of the Americans with
Disabilities Act (ADA) by terminating her employment for the
allegedly pretexual reason of excessive absenteeism. She further
claimed that she was terminated in retaliation for filing a charge
of disability discrimination with the Equal Employment Opportunity
Commission and in retaliation for exercising her rights under the
Family and Medical Leave Act. Granting defendant’s motion for
summary judgment, the district court held that, although plaintiff
had made out a prima facie case of ADA discrimination, she had
failed to carry the two-pronged burden of showing (1) that
defendant’s proffered reasons for terminating her were false;
and (2) that defendant’s real reasons were unlawful.
Plaintiff appealed. The court of appeals held that the district
court had applied an improper standard in requiring plaintiff to
demonstrate that discriminatory reasons motivated defendant’s
decision to terminate her. However, after reviewing the case de
novo, the court affirmed the district court’s decision to
grant defendant summary judgment, finding that defendant had
proffered a facially nondiscriminatory reason for plaintiff’s
termination and that plaintiff did not raise any material issues of
fact as to defendant’s motivation.
