Employee Could Not Establish Disability Discrimination Without A Causal Relationship Between His Impairment And Termination

Category: Fire Watch
Date: Sep 4, 2019 04:05 PM

Jose Valtierra began working for Medtronic, Inc. in 2004 as a facility maintenance technician.  Between his hiring until his termination in 2014, Valtierra was severely overweight.  In late 2013, Valtierra received time off for joint pain associated with his weight.  Valtierra returned to work in December 2013 without medical restrictions; however, he was still morbidly obese. 

In May 2014, Valtierra’s supervisor noticed Valtierra seemed to be having difficulty walking.  Concerned about Valtierra’s ability to perform his job, the supervisor checked the computer system the company used to track assignments.  Although Valtierra had left for vacation a day prior, the computer system indicated that he had completed numerous assignments that should have taken a more significant amount of time to complete. When Valtierra’s supervisor confronted him about these discrepancies, Valtierra admitted he had not performed all of the work, but intended to complete the assignments when he returned from vacation. Medtronic then terminated Valtierra for falsifying records.

Subsequently, Valtierra sued Medtronic alleging that he had a disability within the meaning of the Americans with Disabilities Act (“ADA”) and that his termination was unlawful discrimination. The trial court dismissed Valtierra’s case, finding that obesity, no matter how great, could not constitute a disability under ADA regulations unless the obesity is caused by an underlying condition. The trial court concluded that Valtierra was not able to demonstrate that his obesity was caused by such a condition.

On appeal, the Ninth Circuit affirmed the trial court’s decision to dismiss the case. However, the Ninth Circuit did not decide whether Valtierra’s obesity was a disability under the ADA. Instead, the court found that even assuming that Valtierra was disabled, he could not establish ADA disability discrimination because he could not prove a causal relationship between his obesity and his termination. The court reasoned that because Valtierra admitted he marked assignments as completed when he had not done the work, and because he had been severely overweight throughout his employment, there was no basis to conclude that the company terminated him for any reason other than falsifying records. 

Valtierra v. Medtronic Inc. (2019) 2019 WL 3917531.

NOTE:

Agencies should also be aware that obesity may be a disability within the meaning of the California Fair Employment and Housing Act (“FEHA”) if there is a physiological cause or if the employer perceives of or regards the condition as a disability. Accordingly, public agencies should be sure to carefully evaluate all disability discrimination complaints and requests for accommodation involving obesity.

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