Narrative Opinion Summary
This case involves an appeal by Shelby County against a district court's partial summary judgment in favor of Arthur J. Davis on a retaliatory discharge claim under the Americans with Disabilities Act (ADA). Davis, a deputy tax collector, claimed he was terminated for wearing a mask at work due to respiratory issues and for complaining about air quality, which he alleged was a protected activity under the ADA. The district court granted summary judgment to Davis, asserting that no genuine issue of material fact existed regarding his termination being related to the mask incident. However, Shelby County objected, citing local rules and providing affidavits denying any admission of the firing's relation to the mask. The appellate court conducted a de novo review and found that the district court erred by not considering these affidavits and by failing to require Davis to comply with local rules mandating the designation of material facts and supporting evidence. Consequently, the appellate court reversed the summary judgment, allowing Davis to submit a properly documented motion for summary judgment.
Legal Issues Addressed
Local Rule Compliance in Summary Judgment Motionssubscribe to see similar legal issues
Application: The district court erred by failing to enforce compliance with local rules requiring the designation of material facts and supporting evidence, which undermined the validity of the summary judgment.
Reasoning: Additionally, the district court erred by not addressing Davis's lack of citation, violating Local Rule 7.2(d) of the Western District of Tennessee, which undermines the rule's validity.
Requirements for Summary Judgmentsubscribe to see similar legal issues
Application: Summary judgment is only appropriate if no genuine issue of material fact exists, and the evidence must be viewed in the light most favorable to the non-moving party. In this case, affidavits presented by Shelby County challenged the material facts of the retaliation claim.
Reasoning: The appellate review of this decision is de novo, with summary judgment granted only if no genuine issue of material fact exists, favoring the non-moving party in fact evaluation.
Retaliatory Discharge under the Americans with Disabilities Act (ADA)subscribe to see similar legal issues
Application: The case involves a claim of retaliatory discharge under the ADA, where the plaintiff must show engagement in protected activity, suffering adverse employment action, and a causal connection between the two.
Reasoning: To establish a prima facie case of retaliation, a plaintiff must demonstrate: 1) engagement in protected activity; 2) suffering of adverse employment action; and 3) a causal connection between the adverse action and the protected activity, as outlined in Penny v. United Parcel Svc., 128 F.3d 408, 417 (6th Cir. 1997).