Plaintiff Angela Kendall sued defendant Zoltek Corporation in the United States District Court for the Eastern District of Missouri raising claims of disability discrimination and retaliation under the Americans with Disabilities Act (ADA) and sex discrimination under Title VII. Defendant moved for summary judgment on all claims.
Factual Overview
Kendall worked as a Production Operator at Zoltek’s facility in St. Peters, Missouri, which manufactures wind turbine generators. The position required 12-hour shifts operating machinery, with duties including processing carbon fiber, mixing resin/polymer, feeding fiber into machines, inspecting products, and restocking materials. The written job description required employees to lift 25 pounds overhead, stand for up to 12 hours, and perform various physical movements like lifting, turning, bending, and reaching.
In April 2021, Kendall injured her back after slipping in a puddle at work. Though initially cleared to return without restrictions, she later obtained a doctor’s note requesting sitting time during shifts due to sciatica flare-ups. Zoltek accommodated this request for three months. When Kendall provided updated medical documentation in September 2021, the company reconsidered the accommodation. After meetings with HR about her restrictions, Kendall went on medical leave and eventually received FMLA and short-term disability benefits. Her employment was formally terminated in January 2022.
Legal Analysis
ADA Discrimination: The court found Kendall failed to establish she was a qualified individual under the ADA. Her medical restrictions, which limited her to occasionally lifting no more than 10 pounds and prevented overhead reaching, meant she could not perform essential job functions requiring 25-pound overhead lifts and extended standing. The court determined Zoltek was not required to reallocate essential functions to other employees as an accommodation.
Sex Discrimination: The court rejected Kendall’s Title VII claim that alleged disparate treatment compared to a male employee who was allowed to sit during shifts. The court found Kendall could not establish a prima facie case because she was not qualified to perform the job’s essential functions. Additionally, the court noted Zoltek had legitimate reasons for denying her accommodation requests.
ADA Retaliation: Regarding Kendall’s claim that Zoltek retaliated by threatening to tow her car from an accessible parking spot, the court found insufficient evidence of an adverse employment action. The record showed Kendall was never actually forced to move her car, and other accessible spots remained available.
The court granted summary judgment to Zoltek on all claims, finding no genuine issues of material fact existed for trial.
Schrag on Law 