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Media Alerts - Jacobs v. N.C. Admin. Office of the Courts, et al. -- Fourth Circuit
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April 4, 2015
  Jacobs v. N.C. Admin. Office of the Courts, et al. -- Fourth Circuit
Headline: Face the Facts--Disability Discrimination Case Remanded for Trial After Lower Court Misapplies Summary Judgment Standard

Areas of Law: Civil Procedure, Employment Law

Issues Presented: Whether district court erred in granting summary judgment to employer in a disability discrimination lawsuit when parties disagreed on numerous factual issues.

Brief Summary: Christina Jacobs was a deputy clerk at the New Hanover County Court in North Carolina. Jacobs has suffered from mental illness since childhood, including a recent social anxiety disorder diagnosis. After Jacobs began working at the County Court's front counter, she began to experience extreme stress, nervousness, and panic attacks. In May 2009, Jacobs approached her supervisor Debra Excell and told Excell that she suffered from social anxiety disorder and did not feel healthy working at the front counter. Excell encouraged Jacobs to seek treatment from a doctor and also told Brenda Tucker, the elected clerk of the court, about the meeting. Tucker took handwritten notes and placed them in Jacob's personnel file. Four months later, Jacobs emailed her three immediate supervisors (including Excell) and again disclosed her disability and requested an accommodation. She asked to be trained to fill a different role and work at the front counter only one day a week. When one of the supervisors informed Jacobs that only Tucker could act on her request, Jacobs forwarded her email to Tucker. Tucker was on vacation at the time.

When Tucker returned to the office, she called Jacobs into her office for a meeting with the three supervisors. Tucker told Jacobs that she was being fired because she was not "getting it" and that there was no place Tucker could use Jacobs' services. During her employment with the County Clerk, Jacobs was never written up for any disciplinary infraction or performance issue, and there were no negative notes in her personnel file. After her termination, Jacobs filed suit against the County Clerk's Office and the Clerk of the Court under the Americans with Disabilities Act ("ADA"), alleging disability discrimination, failure to provide a reasonable accommodation, and retaliation. In a brief opinion, the district court granted the County Clerk's motion for summary judgment, finding, among other things, that Jacobs was not disabled as a matter of law, and that there was no evidence in the record that Tucker knew of Jacobs' request for an accommodation at the time she decided to fire Jacobs.

On appeal, the United States Court of Appeals for the Fourth Circuit reversed the district court's finding of summary judgment and remanded for trial on the discrimination, accommodation, and retaliation claims. The court found that the district court's opinion reflected "a clear misapprehension of summary judgment standards" and explained that the standard requires a court to view the evidence in the light most favorable to the non-moving party. Here, the district court improperly resolved numerous factual issues in favor of the County Clerk's Office, the moving party, despite Jacobs' competent evidence to the contrary. The court concluded that several factual issues were in dispute and needed to be resolved at trial.

To read the full text of this opinion, please click here.

Panel: Judges Keenan, Floyd, and Harris

Argument Date: 12/09/2014

Date of Issued Opinion: 03/12/2015

Docket Number: No. 13-2212

Decided: Affirmed in part, reversed in part, and remanded by published opinion.

Case Alert Author: Laura Koman, Univ. of Maryland Carey School of Law

Counsel: ARGUED: Vanessa Katherine Lucas, EDELSTEIN & PAYNE, Raleigh, North Carolina, for Appellant. Kathryn Hicks Shields, NORTH CAROLINA DEPARTMENT OF JUSTICE, Raleigh, North Carolina, for Appellees. ON BRIEF: Lisa Grafstein, Mercedes Restucha-Klem, DISABILITY RIGHTS NORTH CAROLINA, Raleigh, North Carolina, for Appellant. Roy Cooper, North Carolina Attorney General, Grady L. Balentine, Jr., Special Deputy Attorney General, NORTH CAROLINA DEPARTMENT OF JUSTICE, Raleigh, North Carolina, for Appellees. Brian East, DISABILITY RIGHTS TEXAS, Austin, Texas, for Amici Curiae.

Author of Opinion: Judge Floyd

Case Alert Circuit Supervisor: Professor Renée Hutchins

    Posted By: Renee Hutchins @ 04/04/2015 03:29 PM     4th Circuit  

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