Magnus v. St. Mark United Methodist Church
26 Am. Disabilities Cas. (BNA) 1029, 688 F.3d 331, 2012 WL 3194633 (2012)
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Rule of Law:
The Americans with Disabilities Act (ADA) prohibits employment discrimination based on an employee's association with a disabled person, but it does not require an employer to provide a reasonable accommodation, such as a modified work schedule, to a non-disabled employee to care for that person.
Facts:
- Eunice Magnus was re-hired by St. Mark United Methodist Church in 2006 for part-time weekend work, and her supervisor was aware she had a daughter with a disability.
- In February 2008, Magnus accepted a full-time, salaried secretary position with a Monday through Friday schedule.
- In the spring of 2008, the church asked Magnus on three occasions to work weekends to alternate with another secretary, but Magnus refused each time, stating she needed to care for her disabled daughter.
- In November 2008, Reverend McCoy documented Magnus's clerical work deficiencies in a memo to the personnel committee.
- In early January 2009, Magnus received a five percent pay raise, which the church stated was an across-the-board increase given to all full-time employees.
- On Sunday, January 25, 2009, church committee members scheduled a meeting for Wednesday, January 28, to discuss terminating Magnus.
- On Tuesday, January 27, 2009, Magnus arrived at work one hour late due to a medical situation involving her daughter.
- The next day, January 28, 2009, the church terminated Magnus's employment, citing her 'continued poor job performance' and her refusal to work weekends.
Procedural Posture:
- Eunice Magnus filed a lawsuit against St. Mark United Methodist Church in the U.S. District Court for the Northern District of Illinois, alleging associational discrimination under the ADA.
- The church filed a motion for summary judgment, asking the court to rule in its favor without a full trial.
- The district court (trial court) granted summary judgment in favor of the church.
- Eunice Magnus, as the appellant, appealed the district court's decision to the U.S. Court of Appeals for the Seventh Circuit.
- St. Mark United Methodist Church was the appellee in the appeal.
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Issue:
Does an employer violate the Americans with Disabilities Act's (ADA) associational discrimination provision by terminating an employee who refuses to work a required schedule because of the need to care for a disabled relative?
Opinions:
Majority - Tinder, Circuit Judge
No. An employer does not violate the ADA's associational discrimination provision by terminating an employee for failing to meet neutral and legitimate job requirements, even if the failure is due to the employee's need to care for a disabled associate. The court reasoned that the ADA's duty to provide reasonable accommodation applies only to employees who are themselves disabled, not to non-disabled employees who have disabled relatives. Magnus was terminated for two legitimate, non-discriminatory reasons: documented poor job performance and her refusal to work weekends, a requirement of the job. The timing of her termination, one day after she was late due to her daughter's medical issue, was not sufficient to infer a discriminatory motive because evidence showed the decision to terminate her had been made the prior weekend. Therefore, the church's actions were based on Magnus's failure to meet job requirements, not on unfounded assumptions about her association with her disabled daughter.
Analysis:
This decision clarifies the limited scope of the ADA's associational discrimination provision. It establishes a firm line between prohibiting adverse actions based on stereotypes or assumptions about caregiving responsibilities and an employer's right to enforce neutral work policies. The case reinforces that an employee's inability to meet legitimate attendance or scheduling requirements is not protected, even if motivated by a commendable commitment to care for a disabled family member. Future cases will likely rely on this precedent to distinguish between impermissible discrimination based on unfounded fears and permissible termination based on an employee's actual failure to perform essential job functions.
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