Plaintiff Orville McDonald sued defendant Missouri Department of Corrections and several individual defendants in the United States District Court for the Eastern District of Missouri raising claims of disability discrimination under the Americans with Disabilities Act (ADA), the Rehabilitation Act, the Missouri Human Rights Act (MHRA), and constitutional violations under 42 U.S.C. § 1983. Defendants moved to dismiss plaintiff’s claims under Rule 12(b)(6).
Factual Overview
McDonald was employed as a corrections officer by the Missouri Department of Corrections (MDOC) from 2004 until his termination on April 18, 2023. During his employment, McDonald developed anxiety and depression due to exposure to violence at work. In May 2022, McDonald notified MDOC of his disabilities and requested reasonable accommodations under the ADA. MDOC initially approved accommodations, allowing McDonald to work at the sally port gate. However, between December 2022 and April 2023, McDonald was removed from this post 27 times. After repeatedly complaining about lack of proper accommodations, McDonald was terminated on April 18, 2023.
McDonald filed a Charge of Discrimination with the EEOC and the Missouri Commission on Human Rights. After receiving a right to sue letter, McDonald filed this lawsuit alleging violations of the ADA, Rehabilitation Act, MHRA, and constitutional rights under § 1983.
Legal Analysis
ADA Claim: The court first addressed whether McDonald’s ADA claim could proceed under Title II rather than Title I. The court found that the majority of federal circuits have held that claims of discrimination in public employment are not properly raised under Title II of the ADA. Following this majority view, the court dismissed McDonald’s ADA claim for failure to state a claim.
MHRA Claim: The court then examined McDonald’s claim under the MHRA. The court found that McDonald failed to adequately allege the elements of a disability discrimination claim under the MHRA. Specifically, McDonald did not provide sufficient factual allegations regarding how his anxiety and depression substantially limit a major life activity, whether he could perform the essential functions of his job with reasonable accommodation, or that his disabilities were the motivating factor in the alleged adverse employment actions. The court dismissed the MHRA claim for failure to state a claim.
Section 1983 Claims: Finally, the court addressed McDonald’s § 1983 claims against the individual defendants in both their official and individual capacities. The court found that the individual defendants had sovereign immunity from § 1983 claims brought against them in their official capacities. As for the claims against the defendants in their individual capacities, the court determined that the defendants were entitled to qualified immunity. The court noted that McDonald failed to establish that failing to provide reasonable accommodations in employment or firing a disabled state employee violates the Eighth Amendment, or that such rights were clearly established at the time of the alleged actions.
The court granted the defendants’ motion to dismiss and dismissed all of McDonald’s claims without prejudice for failure to state a claim.
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