In Terry L. Anderson v. Textron Aviation, Inc. d/b/a Cessna, the plaintiff, Terry L. Anderson, sued under the Americans with Disabilities Act (ADA) against his former employer, Textron Aviation, Inc. Anderson alleged that Textron terminated his employment due to his disabilities—a violation of the ADA.
Plaintiff’s Factual Allegations
Anderson, who has diabetes and related cellulitis, managed his condition with diet and medication. He had been employed by Textron (or its predecessor, Cessna Aircraft Company) since August 29, 1995, working as an aircraft spray painter and a Safety Advocate. The events leading to his termination began in early March 2021 when his immediate supervisor, Timothy Thayer, informed him about two people in his department contracting COVID-19. Anderson was offered the opportunity to quarantine, which he declined. Subsequently, on March 3, 2021, Anderson met with Human Resources (HR) to express concerns about Textron’s compliance with COVID protocols, particularly the timely notification of potential exposure.
Anderson’s wife, Twyla, also participated in the meeting via phone, echoing concerns about their health risks due to underlying conditions and questioning Textron’s exposure notification protocols. She suggested that Textron might not be complying with the law and considered the possibility of retaining legal counsel. The situation escalated on March 17, 2021, when Anderson reported a slip and fall incident while cleaning water. Thayer, however, doubted the consistency of Anderson’s account of the incident, leading to an HR investigation. The investigation concluded that Anderson had breached the trust policy by providing false information about the incident, resulting in his termination on April 9, 2021.
Court’s Analysis of Legal Issues
Issue 1: Prima Facie Case for Disability Discrimination
The court examined whether Anderson established a prima facie case for disability discrimination under the ADA. The ADA defines disability as a physical or mental impairment that substantially limits one or more major life activities. Anderson contended that his diabetes and cellulitis were disabilities as they limited his endocrine functions and ability to work. The court found that his diabetes qualified as a disability under the ADA because it substantially limited his endocrine functions. That said, it did not find substantial evidence that his conditions limited his ability to work.
Issue 2: Non-discriminatory Reason for Termination
Textron, in response, provided a legitimate, nondiscriminatory reason for Anderson’s termination, citing breach of trust. The company’s investigation into the slip and fall incident led to the conclusion that Anderson had provided false information, a violation of the company’s policy. This reason satisfied Textron’s burden to articulate a nondiscriminatory reason for the termination.
Issue 3: Analysis of Pretext
The court then analyzed whether Anderson could show that Textron’s stated reason for termination was pretextual. Anderson argued that he had not made inconsistent statements and questioned the logic of terminating an employee over such a discrepancy. But the court found that Anderson failed to provide evidence that Textron’s decision was pretextual or that his disability played any role in the termination decision. The court determined that Textron had a good-faith belief that Anderson violated the breach of trust policy, and there was no genuine issue of fact that the stated reason was pretextual.
Court’s Conclusion Based on these findings, the court granted Textron’s motion for summary judgment, dismissing Anderson’s claims of disability discrimination.
Schrag on Law 