Narrative Opinion Summary
The case of Barreca v. Travco Behavioral Health, Inc. involved a disability discrimination claim under Ohio law, where the appellant argued that her termination was based on her multiple sclerosis. The Court of Appeals for the Eleventh Appellate District upheld a summary judgment in favor of the appellee, Travco Behavioral Health, Inc. The court found that the appellant did not provide sufficient evidence to establish a prima facie case of disability discrimination under R.C. 4112.01(A)(13) and 4112.02(A), as her multiple sclerosis was not shown to substantially limit her major life activities. The court noted her ability to walk and drive was unaffected, and the appellant failed to counter the appellee's evidence indicating no limitations. The procedural history included the appellant's filing of a claim with the Ohio Civil Rights Commission and subsequent legal action, which resulted in a motion for summary judgment by the appellee. The appellant's claim of intentional infliction of emotional distress was not contested on appeal. The court concluded that summary judgment was appropriate, given the lack of evidence linking her condition to any adverse employment action, thereby affirming the lower court's decision.
Legal Issues Addressed
Definition of Disability under Ohio Lawsubscribe to see similar legal issues
Application: The court found that the appellant's multiple sclerosis did not meet the statutory definition of a disability as it did not substantially limit her major life activities.
Reasoning: R.C. 4112.01(A)(13) defines 'disability' as a physical or mental impairment that significantly limits major life activities, such as self-care, manual tasks, and mobility.
Evidence Required to Prove Disabilitysubscribe to see similar legal issues
Application: The appellant did not provide evidence to counter the appellee's documentation that she had no limitations due to multiple sclerosis, which was crucial for her claim.
Reasoning: The plaintiff's own deposition revealed that her physician indicated she had no limitations due to multiple sclerosis and that the condition did not significantly affect her mobility or ability to drive.
Prima Facie Case of Disability Discriminationsubscribe to see similar legal issues
Application: The appellant failed to establish a prima facie case because she could not demonstrate that her multiple sclerosis substantially limited her major life activities or that her termination was due to her condition.
Reasoning: To establish a prima facie case of disability discrimination, a claimant must show: (1) they are disabled, (2) that an adverse employment action was taken due to this disability, and (3) that they can perform essential job functions despite the disability.
Summary Judgment in Discrimination Casessubscribe to see similar legal issues
Application: The court affirmed summary judgment in favor of the appellee due to the appellant's failure to present evidence of a substantial limitation caused by her condition.
Reasoning: The court emphasized that summary judgment is appropriate when no genuine material fact exists, and the moving party is entitled to judgment as a matter of law.