Plaintiff Don Christensen sued defendant Triumph Aerostructures-Tulsa, LLC in the United States District Court for the Northern District of Oklahoma, raising claims of discrimination under the Americans with Disabilities Act (ADA) and the Age Discrimination in Employment Act (ADEA). Before the court is Defendant Triumph’s motion for summary judgment.
Statement of Undisputed Facts:
Christensen worked as a Level 4 industrial engineer for Triumph from 2014 to 2016. In 2015, he disclosed an unspecified disability to Triumph. In 2016, Christensen was transferred to a new project that required him to work on an upper floor. He requested accommodation to work on the ground floor due to mobility issues. There was a delay of over a month in granting this accommodation. In October 2016, Triumph conducted a reduction in force (RIF) and terminated Christensen’s employment. Christensen received the lowest score on a RIF Assessment worksheet compared to other engineers in his department.
The court noted several evidentiary disputes. There were inconsistencies in the dates provided for certain events in the parties’ briefings compared to the supporting exhibits. Additionally, some cited pages were missing from the exhibits filed by both parties. The court admonished counsel to be more careful in making statements not supported by the submitted evidence.
Legal Analysis:
ADA Discrimination: The court applied the McDonnell Douglas burden-shifting framework to analyze Christensen’s ADA discrimination claim. The court found that Christensen established a prima facie case of failure to accommodate. Triumph failed to conclusively rebut this or establish an affirmative defense. The court determined that a reasonable jury could find Triumph did not act in good faith in responding to Christensen’s accommodation request, given the unexplained delay and lack of interim accommodations.
ADA Retaliation: The court found that Christensen barely met his burden of establishing a prima facie case of retaliation. While the temporal proximity between his accommodation request and termination was insufficient on its own, the court found that Triumph’s lack of standard documentation for the RIF and ambiguities surrounding the RIF Assessment could allow a reasonable factfinder to infer pretext.
ADEA Claim: The court determined that Christensen failed to establish a prima facie case under the ADEA. He did not provide evidence that he was doing satisfactory work or that age was the determining factor in his termination. The court found that any discriminatory animus could only be speculatively attributed to age rather than disability or other factors.
The court granted summary judgment on Christensen’s ADEA claim but denied summary judgment on his ADA discrimination and retaliation claims.
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