Ctr., No. SD38287 (Mo. Ct. App. Aug. 13, 2024) (J. Burrell)
John Lackey sued Phelps County Regional Medical Center in the Circuit Court of Phelps County, Missouri, raising claims of disability discrimination under the Missouri Human Rights Act (MHRA). The circuit court granted summary judgment in favor of the defendant, and Lackey appealed to the Missouri Court of Appeals, Southern District.
Factual Overview
John Lackey was employed by Phelps County Regional Medical Center as a Safety Specialist from 2006 to July 19, 2019. In late 2018 and early 2019, the medical center decided to reorganize to better meet hospital accreditation requirements. As part of this reorganization, Lackey’s Safety Specialist position was eliminated, and a new position of Assistant Director of Safety and Compliance was created. This new position had a higher level of authority and different expectations for knowledge, expertise, background, and education compared to Lackey’s previous role.
Lackey and an external candidate, Matt Dennon, were interviewed for the new position. Ultimately, the medical center hired Dennon. Lackey then sued the medical center, claiming that he was physically disabled and that his alleged disability contributed to the medical center’s decision not to hire him for the new position. Lackey also claimed that he was subjected to discrimination and harassment based on his physical disability.
Legal Analysis
Disability Discrimination Under MHRA: The court outlined the requirements for proving a disability discrimination claim under the MHRA. A claimant must show that they (1) were disabled, (2) were discharged or suffered some other adverse employment action forbidden by the statute, and (3) their disability was a factor in the adverse employment action or discharge.
Definition of Disability: The court noted that under the MHRA, a disability is defined as “a physical or mental impairment which substantially limits one or more of a person’s major life activities, being regarded as having such an impairment, or a record of having such an impairment, which with or without reasonable accommodation does not interfere with performing the job.”
Summary Judgment Analysis: The court found that the medical center made a prima facie showing of a right to summary judgment by negating the required element that Lackey was disabled. The medical center presented Lackey’s own deposition testimony, in which he stated that he did not have any physical or mental impairments that substantially limited one or more of his major life activities during the relevant time period.
Plaintiff’s Burden to Show Genuine Dispute: Once the medical center made its prima facie case, the burden shifted to Lackey to show that there was a genuine dispute about whether he was disabled. The court found that Lackey failed to meet this burden. While Lackey cited medical records to support his claim of disability, these records were not provided to the medical center until after the lawsuit was filed, well after the decision not to hire Lackey for the new position was made.
Knowledge of Disability: The court emphasized that Lackey failed to provide any evidence that the medical center knew he claimed to be disabled before making the decision not to hire him for the Assistant Director position. This lack of evidence was fatal to Lackey’s claim.
The Missouri Court of Appeals affirmed the circuit court’s grant of summary judgment in favor of Phelps County Regional Medical Center on Lackey’s disability discrimination claim under the MHRA.
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