Shaneca Louise Davis sued Chenega Corporation in the United States District Court for the Eastern District of Missouri, alleging employment discrimination under the Americans with Disabilities Act (ADA). Defendant Chenega Analytic Business Solutions, LLC moved to dismiss the plaintiff’s First Amended Complaint for failure to state a claim.
Factual Overview
Davis alleged she had dyslexia and worked for Chenega Corporation. When she requested accommodations, the company required her to provide documentation of her condition and recommendations for specific accommodations. Davis believed the company should have taken her word about her condition without requiring documentation. She admitted taking an unauthorized extended lunch break and improperly sharing personally identifiable information during her employment. Davis also acknowledged she “was not able to understand fully” what her job entailed. The company terminated her employment.
Legal Analysis
Disability Status Under the ADA: The court found Davis failed to establish she had a disability as defined by the ADA. While she alleged she had dyslexia, she did not demonstrate how this condition substantially limited any major life activity. The court noted Davis’s last documentation of her condition predated her elementary school years.
Failure to Accommodate: Even assuming Davis had a qualifying disability, the court determined she failed to establish a failure to accommodate claim. The court found the employer could properly require documentation of her condition and proposed accommodations rather than simply taking her word. Additionally, Davis never identified any specific accommodation she requested that was denied.
Discriminatory Termination: The court concluded Davis failed to show her termination was based on her alleged disability. Instead, her own complaint admitted to policy violations including an unauthorized extended lunch break and improper sharing of confidential information. The court found these provided an obvious alternative explanation for her termination.
Hostile Work Environment: The court determined Davis failed to identify any harassment based on disability that was sufficiently severe or pervasive to create a hostile work environment.
The court granted the defendant’s motion and dismissed Davis’s claims with prejudice, finding she failed to state any viable claim under the ADA.
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