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Muttersbaugh v. Hyundai Motor Manufacturing of Alabama, LLC

United States District Court, M.D. Alabama, Northern Division

May 24, 2019

CHRISTOPHER MUTTERSBAUGH, Plaintiff,
v.
HYUNDAI MOTOR MANUFACTURING OF ALABAMA, LLC, Defendant.

          OPINION AND ORDER

          MYRON H. THOMPSON UNITED STATES DISTRICT JUDGE

         Plaintiff Christopher Muttersbaugh brought this lawsuit pursuant to the Americans with Disabilities Act, as amended (ADA), 42 U.S.C. § 12101 et seq., against his former employer, defendant Hyundai Motor Manufacturing of Alabama, LLC. Muttersbaugh asserts five claims: (1) failure to accommodate, (2) retaliatory failure to promote, (3) retaliatory termination, (4) general retaliation, and (5) discriminatory termination. Pending before the court is Hyundai's motion for summary judgment on all of Muttersbaugh's claims. The magistrate judge recommends granting summary judgment on all claims. After reviewing the record and holding oral argument on the magistrate judge's recommendation, the court concludes, as follows, that the motion should be granted as to all claims except the failure-to-accommodate claim, which will go to trial:

(1) Failure to Accommodate: The magistrate judge inappropriately recommends summary judgment on this claim. He concluded the claim was untimely, and that, even if timely, it would not survive summary judgment because Muttersbaugh was not denied an accommodation. For the reasons discussed below, the court finds that there is a factual dispute as to whether the claim is time-barred. Furthermore, there are disputes of material fact, precluding summary judgment, as to when Muttersbaugh's supervisor prevented him from eating and whether any accommodation Muttersbaugh was provided with was effective.
(2) Retaliatory Failure to Promote: The magistrate judge inappropriately applied the discriminatory failure-to-promote test, rather than the retaliatory one. Applying the retaliatory failure-to-promote test, this claim should not survive summary judgment because Muttersbaugh showed no evidence, beyond impermissible hearsay statements, that raise a specter of retaliation.
(3) Retaliatory Termination: The magistrate judge properly concluded that summary judgment was appropriate on this claim because Muttersbaugh failed to show sufficient pretext to rebut Hyundai's legitimate, non-retaliatory reason for firing him.
(4) Claim of Other Assertions of Retaliation: The magistrate judge properly concluded that this claim is time-barred.
(5) Discriminatory Termination: The magistrate judge properly concluded that summary judgment was appropriate on this claim because Muttersbaugh failed to show sufficient pretext to rebut Hyundai's legitimate, non-discriminatory reason for firing him.

         I. SUMMARY-JUDGMENT STANDARD

         “A party may move for summary judgment, identifying each claim or defense--or the part of each claim or defense--on which summary judgment is sought. The court shall grant summary judgment if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed.R.Civ.P. 56(a). The court must view the admissible evidence in the light most favorable to the non-moving party and draw all reasonable inferences in favor of that party. See Matsushita Elec. Indus. Co., Ltd. v. Zenith Radio Corp., 475 U.S. 574, 587 (1986).

         II. FACTUAL BACKGROUND

         The alleged facts viewed in favor of Muttersbaugh are as follows.

         Muttersbaugh worked as a Warranty Reclaim Specialist at Hyundai from May 2010 to February 2013, when he was terminated. His position required him to review warranty claims and handle payments or charge backs to Hyundai suppliers. His direct supervisor was Jennifer Bayless, and her supervisor was Mark Rylatt.

         Muttersbaugh requested reasonable accommodations for type 1 diabetes.

         Muttersbaugh has type 1 diabetes and needs to eat throughout the day to maintain his blood-sugar levels. If he experiences low or high blood-sugar events, the impact can range from momentary weakness to loss of consciousness. In order to manage his diabetes in the workplace, he requested reasonable accommodations from his supervisors Bayless and Rylatt shortly after he was hired. Specifically, he requested being allowed to eat meals and snacks on a routine basis, working consistent hours (including having a consistent start time) and taking time off for diabetes-related doctors' appointments and diabetic episodes.

         Throughout Muttersbaugh's employment, supervisor Rylatt prevented him from using his reasonable accommodations and made fun of his disability.

         For example, in 2010, Muttersbaugh had a severe insulin reaction in Hyundai's parking lot, and a coworker called for medical attention. The next day, Rylatt told Muttersbaugh that he had either heard or seen Muttersbaugh “flopping around like a fish out of water” either in an ambulance or on a stretcher. Muttersbaugh Declaration (doc. no. 31-3) at 3. Rylatt admitted that he heard about the incident in the parking lot but denied make derogatory comments about it. Furthermore, when Rylatt would see Muttersbaugh eating a meal or snack at his desk, Rylatt would criticize him for not working and tell him that he needed an assignment to be completed immediately. These interruptions forced Muttersbaugh to delay his meal or snack.

         Rylatt retaliated against Muttersbaugh, throughout his employment, for requesting reasonable accommodations and reporting Rylatt's discriminatory behavior.

         Rylatt retaliated against Muttersbaugh in the following ways:

(1) Rylatt gave Muttersbaugh lower end-of-year performance reviews for the years 2010 and 2011.
(2) Rylatt told Muttersbaugh he was required to use vacation time for doctor's appointments, even though that is not Hyundai's policy.
(3) Rylatt subjected Muttersbaugh to heightened scrutiny.
(4) Rylatt expressed frustration with Muttersbaugh when he was away from his desk for 20 minutes due to having an insulin reaction.
(5) Rylatt reported false information to attempt to discipline Muttersbaugh.
(6) Rylatt expressed frustration with Muttersbaugh that he met with Hyundai's Human Resources and said he would not pay him overtime for the meeting.
(7) Rylatt told the individual, who was in charge of hiring Muttersbaugh in a different department, not to choose him.
(8) Rylatt “forced” Bayless to discipline Muttersbaugh even when she found it inappropriate.
(9) Rylatt's discriminatory animus led to Muttersbaugh's termination.

         Muttersbaugh's job duties changed and his request to remain on his ...


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