Disability Discrimination And Hostile Work Environment Claims Fail
Affirming the United States District Court’s grant of summary judgment for the defendant in this suit by a former government agency employee alleging disability discrimination, failure to accommodate, and a hostile work environment, the 1st Circuit held that: (1) there was no direct evidence of discrimination against the employee based on her disability, as required to entitle the employee to a mixed motive analysis on her employment discrimination claim; (2) the employee was not a qualified individual able to perform the essential functions of her job, as required to support her disability discrimination and reasonable accommodation claims; (3) the employer articulated a legitimate, non-discriminatory reason for terminating the employee's temporary promotion; and (4) the incidents alleged by the employee were insufficient to raise a triable issue of fact as to the employee's claim for hostile work environment.
Rios-Jimenez v. Sec'y of Veterans Affairs
The 1st Circuit Court of Appeals’ jurisdiction includes Maine, Massachusetts, New Hampshire, Puerto Rico and Rhode Island.