Plaintiff Juanita Jones sued defendants Olin Winchester, LLC, Olin Corporation, and Winchester Ammunition, Inc. in the United States District Court for the Western District of Missouri, raising claims of race, age, and disability discrimination under Title VII, the ADEA, the ADA, and the MHRA. Defendants moved to dismiss plaintiff’s claims under Rule 12(b)(6).
Factual Overview
Plaintiff Juanita Jones was diagnosed with diabetes, suffered a heart attack, and developed several heart-related medical conditions in 2010 and 2011. In December 2015, she became employed as an inspector at an ammunition factory, which changed ownership several times. In October 2020, Olin Winchester placed plaintiff in a position requiring frequent heavy lifting, which she had not been required to do previously. Plaintiff requested a reasonable accommodation based on a lifting restriction issued by her doctor, but Olin Winchester allegedly did not provide it. As a result, plaintiff began suffering chest pains and requested intermittent leave.
Throughout 2021, plaintiff received warnings for missing work and not being at her workstation on time, despite believing her absences were covered by approved intermittent leave. In September 2021, plaintiff suffered an accident outside of work resulting in a leave of absence. In December 2021, plaintiff filed an administrative charge with the EEOC and MCHR alleging discrimination based on age and disability. Plaintiff’s health insurance was discontinued in December 2021. In March 2022, Olin Winchester terminated plaintiff’s employment after she informed her supervisor she had not been medically cleared to return to work following a COVID-19 diagnosis. Plaintiff filed an amended administrative charge in July 2022 and subsequently filed this lawsuit in December 2023.
Legal Analysis
Administrative Exhaustion: The court found that most of plaintiff’s claims were not administratively exhausted. Plaintiff’s failure to accommodate claim was time-barred because it occurred outside the scope of her administrative charge. Plaintiff did not exhaust her race discrimination, hostile work environment, and retaliation claims because they were not included in her administrative charges. Additionally, plaintiff did not exhaust her claims regarding her termination and the alleged discontinuation of her health benefits.
Age and Disability Discrimination under Title VII: The court dismissed plaintiff’s age and disability discrimination claims under Title VII, finding that such claims are not actionable under that statute.
Age and Disability Discrimination under the ADEA, ADA, and MHRA: The court dismissed plaintiff’s age and disability discrimination claims under the ADEA, ADA, and MHRA because they were not supported by an adverse employment action. Plaintiff’s termination, alleged discontinuation of health insurance, and alleged failure to accommodate were not properly exhausted and could not support her discrimination claims. The disciplinary warnings plaintiff received did not constitute adverse employment actions because they were unaccompanied by a change in working conditions.
The court granted defendants’ motion to dismiss and dismissed the case.
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