United States District Court, E.D. Arkansas, Western Division
MEMORANDUM AND ORDER
JOE J. VOLPE, Magistrate Judge.
Plaintiff, Javonda Scruggs, brings this action alleging violation of the Americans with Disabilities Act (ADA), the Arkansas Civil Rights Act (ACRA), Section 504 of the Rehabilitation Act, the Family and Medical Leave Act (FMLA), and race and gender discrimination pursuant to 42 U.S.C. § 1983 and the ACRA (Doc. No. 3). Defendant, Pulaski County, has moved for summary judgment (Doc. Nos. 13-15). Plaintiff has responded (Doc. Nos. 27-29), and Defendant replied (Doc. No. 30). Therefore, the matter is now ripe for disposition. After careful consideration of the pleadings, for the specific reasons outlined below, the Court concludes summary judgment is appropriate and this matter should be dismissed with prejudice.
Ms. Scruggs was employed as a Pulaski County Juvenile Detention Officer from 2001 to May 21, 2013. Ms. Scruggs has a number of health problems, including fibromyalgia and degenerative disc disease. She has worked despite her medical impairments and, as necessary, exercised unpaid leave pursuant to the Family and Medical Leave Act (FMLA), 29 U.S.C. §§ 2601-2654. Ms. Scruggs's condition worsened over the years, and in February 2013, one of her treating physicians, Christopher Mocek, M.D., placed significant work restrictions upon her. Those restrictions included "no sitting, standing, bending, stooping for extended periods, " as well as a prohibition on lifting "more than 25 lbs." (Doc. No. 14-5 at 9.) Given these restrictions, Pulaski County officials determined Ms. Scruggs could not perform the job and placed her on continuous FMLA leave until it expired on May 15, 2013. On May 21, 2013, Pulaski County terminated Ms. Scruggs's employment.
III. SUMMARY JUDGMENT STANDARD
Summary judgment is appropriate only when there is no genuine issue of material fact, so that the dispute may be decided on purely legal grounds. Holloway v. Lockhart, 813 F.2d 874 (8th Cir. 1987); Fed.R.Civ.P. 56. Summary judgment will be granted only after viewing the evidence and drawing all reasonable inferences in the light most favorable to the nonmovant, and then finding that no genuine issues of material fact exist. Nelson v. Corr. Med. Servs., 533 F.3d 958, 961 (8th Cir. 2008) (citing Fed. R. Civ.P. 56); see also Brown v. Fortner, 518 F.3d 552, 558 (8th Cir. 2008). The United States Supreme Court has established guidelines to assist trial courts in determining whether this standard has been met: "The inquiry performed is the threshold inquiry of determining whether there is the need for a trial - whether, in other words, there are any genuine factual issues that properly can be resolved only by a finder of fact because they may reasonably be resolved in favor of either party." Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 250 (1986).
The United States Court of Appeals for the Eighth Circuit has held "that summary judgment should seldom be granted in the context of employment actions, as such actions are inherently fact based." Keathley v. Ameritech Corp., 187 F.3d 915, 919 (8th Cir. 1999). Nevertheless, summary judgment promotes judicial economy by preventing trial when no genuine issue of fact remains. Inland Oil & Transport Co. v. United States, 600 F.2d 725, 727 (8th Cir. 1979). This Court must view the facts in the light most favorable to the party opposing the motion. Id. at 727-28. The United States Court of Appeals for the Eighth Circuit has also set out the burden of the parties in connection with a summary judgment motion:
[T]he burden on the party moving for summary judgment is only to demonstrate, i.e., "[to point] out to the District Court, " that the record does not disclose a genuine dispute on a material fact. It is enough for the movant to bring up the fact that the record does not contain such an issue and to identify that part of the record which bears out his assertion. Once this is done, his burden is discharged, and, if the record in fact bears out the claim that no genuine dispute exists on any material fact, it is then the respondent's burden to set forth affirmative evidence, specific facts, showing that there is a genuine dispute on that issue. If the respondent fails to carry that burden, summary judgment should be granted.
Counts v. MK-Ferguson Co., 862 F.2d 1338, 1339 (8th Cir. 1988).
Only disputes over facts that may affect the outcome of the suit under governing law will properly preclude the entry of summary judgment. Anderson, 477 U.S. at 248. "Evidence, not contentions, avoids summary judgment." Mayer v. Nextel West Corp., 318 F.3d 803, 809 (8th Cir. 2003).
Ms. Scruggs's disability discrimination claims must be analyzed under the burden-shifting framework of McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973). Under McDonnell Douglas, the plaintiff must first establish a prima facie case of discrimination. The burden of production then shifts to the employer, who must articulate some legitimate, nondiscriminatory reason for the employment decision. McDonnell Douglas, 411 U.S. at 802.
A. Race and ...