Narrative Opinion Summary
In this case, a substitute special education aide applied for a full-time position with a school district, which was contingent upon passing a physical examination. After being deemed 'medically unsuitable' due to mobility limitations from a previous stroke, the district rescinded her job offer and terminated her substitute role. The aide filed a lawsuit under the Fair Employment and Housing Act (FEHA) claiming disability discrimination, failure to accommodate, and retaliation, among others. The trial court granted summary judgment in favor of the district, but the appellate court found triable issues of fact regarding the disability discrimination claim. The court applied the McDonnell Douglas burden-shifting framework, requiring the plaintiff to show a prima facie case of discrimination, which the appellate court found she had done. However, her failure to engage in the interactive process and accommodation claims were dismissed as she did not request accommodations or disclose her disability. The court also found no causal connection for the retaliation claim as the adverse action predated any alleged protected activities. The appellate court reversed the summary judgment on the discrimination claim but upheld it on other claims, directing the trial court to proceed with the remaining issues.
Legal Issues Addressed
Disability Discrimination under Fair Employment and Housing Act (FEHA)subscribe to see similar legal issues
Application: The case examines whether the employer perceived Price as disabled, leading to adverse employment actions based on her physical examination results.
Reasoning: Triable material facts exist regarding all three elements. Price can argue that the District regarded her as disabled based on a failed physical examination, where deficiencies in her right leg were noted, leading to the rescinding of her job offer.
Essential Job Functions and Disabilitysubscribe to see similar legal issues
Application: The court identified a factual dispute regarding whether running after students was an essential function of the Instructional Assistant position, warranting jury consideration.
Reasoning: The determination of essential job functions is fact-specific and typically a matter for jury consideration.
Failure to Accommodate under FEHAsubscribe to see similar legal issues
Application: Price's claim of failure to accommodate was dismissed because she did not request accommodation, and her disability was not obvious to trigger an interactive process.
Reasoning: Price did not assert that her disability and limitations were apparent to the District; instead, she indicated on her application that she had no disabilities or limitations and required no accommodations.
Failure to Engage in the Interactive Process under FEHAsubscribe to see similar legal issues
Application: The court found no obligation for the District to engage in an interactive process, as Price did not disclose her disability or request accommodations.
Reasoning: Although Price argued that Dickinson obstructed her attempts to engage in the interactive process... the court maintained that because Price's disability was not evident, it was her responsibility to inform the District of her disability and limitations.
Retaliation under FEHAsubscribe to see similar legal issues
Application: The court concluded that Price's retaliation claim lacked merit because the alleged protected activities occurred after the adverse employment action.
Reasoning: Price contended she engaged in protected activities by questioning her supervisor and attempting to communicate her medical status. However, the court noted that the adverse action (termination) occurred before these activities, indicating a lack of causal link.
Summary Judgment Standardssubscribe to see similar legal issues
Application: The appellate court reversed the summary judgment on the disability discrimination claim, finding triable issues of fact, but upheld the summary judgment on other claims due to lack of evidence.
Reasoning: The denial of a motion for summary judgment is reviewed de novo, with a strict interpretation of the moving party’s affidavits and a liberal interpretation of those from the opposing party.