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Keywords

motionsummary judgmentdiscriminationrehabilitation
plaintiffsummary judgmentdiscriminationrehabilitation

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Scott v. Napolitano

Facts

James Scott was hired by the Federal Protective Service in 1991 and promoted to Special Agent in 1992. He suffered from various health issues, including an adjustment disorder and repetitive motion injuries, which led to periods of disability. In 2005, after being directed to undergo fitness-for-duty examinations, Scott refused to answer certain medical questions he deemed inappropriate, leading to disciplinary actions including a suspension and eventual termination in 2007.

In 1991, Plaintiff James Scott ('Plaintiff') was hired by the Federal Protective Service ('FPS') as a uniformed federal protective officer in Los Angeles, California.

Issue

The main legal issues were whether the employer's medical inquiries violated the Rehabilitation Act, whether the employer retaliated against the employee for opposing those inquiries, and whether the employee was discriminated against based on age.

The employee alleged that the employer violated the Rehabilitation Act/Americans with Disabilities Act (ADA) by making impermissible disability-related inquiries; retaliated against him by suspending him and terminating him for opposing those inquiries; and violated the ADEA by subjecting him to periodic, age-based medical examinations.

Rule

The court applied the standards of the Rehabilitation Act and the ADEA, focusing on whether the employer's inquiries were job-related and consistent with business necessity, and whether the employee's refusal to answer those inquiries constituted protected activity under the law.

The court concluded, first, that the questions that the employee refused to answer on his medical exam form were overbroad in scope and time.

Analysis

The court found that the employer's medical inquiries were overly broad and not tailored to assess the employee's ability to perform his job, thus violating the Rehabilitation Act. Additionally, the court determined that the employer did not provide sufficient evidence to support its mixed-motive defense regarding the retaliation claim, as the employee had established a prima facie case.

Second, in the face of the employee's prima facie case of retaliation, the employer failed to present sufficient evidence to support summary judgment based on the mixed-motive defense–i.e., that the employee would have been suspended and terminated even if he had answered the disability-related inquiries on his medical exam form.

Conclusion

The court granted summary judgment for the employer on the claims of disability discrimination and age discrimination, but denied it on the retaliation claim under the Rehabilitation Act.

Summary judgment was granted for the employer on the employee's claims for disability discrimination under the Rehabilitation Act/ADA, retaliation under Title VII, and violation of the ADEA.

Who won?

The employer prevailed on the claims for disability discrimination and age discrimination because the court found the inquiries were permissible under the law. However, the court did not grant summary judgment on the retaliation claim, indicating that the employee had a valid claim.

Summary judgment was granted for the employer on the employee's claims for disability discrimination under the Rehabilitation Act/ADA, retaliation under Title VII, and violation of the ADEA.

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