Jason Gati v. Western Kentucky University

Summary

In this unpublished Sixth Circuit case, the court affirmed summary judgment for Western Kentucky University on claims under the ADA, Rehabilitation Act, and Kentucky Civil Rights Act, holding that the university did not fail to reasonably accommodate a disabled student when it declined to offer courses via Interactive Television or at a satellite campus because such accommodations would fundamentally alter the academic program. The court emphasized that the student bore the initial burden of proving his proposed accommodations were reasonable and that the university’s alternative offer of on-campus housing was reasonable; it also gave significant deference to the university’s academic judgment in structuring its clinical counseling curriculum. Additionally, the court barred state-law claims against officials in their official capacities under Eleventh Amendment immunity and held that the admissions counselor’s ministerial conduct did not support claims of promissory estoppel, fraud, or tortious interference.

Holdings

1. No rational jury could find Gati's proposed accommodations reasonable. The university's offer of on-campus housing was a reasonable accommodation, and Gati's rejection of it means he is not a qualified individual with a disability as a matter of law. Therefore, summary judgment was proper.
2. Because Gati failed to make a prima facie case of discrimination against WKU, the aiding and abetting claim fails as a matter of law.
3. The Eleventh Amendment bars federal courts from hearing state law claims against state officials in their official capacity without explicit waiver of immunity, and Kentucky has not waived immunity for these claims. Therefore, the official-capacity claims are dismissed.
4. The promissory estoppel claim fails because Priddy made no promises; the fraud claim fails because Gati presented no evidence that Priddy knew her statements were false; the tortious interference claim fails because Gati did not show improper interference.

Questions Presented

1. Whether the district court correctly granted summary judgment on Gati's disability discrimination claims under the ADA, Rehabilitation Act, and KCRA because his proposed accommodations were unreasonable.
2. Whether the district court correctly dismissed the aiding and abetting claim against Kline and Priddy under KRS § 344.280.
3. Whether the official-capacity state law claims against Priddy are barred by the Eleventh Amendment.
4. Whether the individual-capacity tort claims against Priddy for promissory estoppel, fraud, and tortious interference fail.

Disposition

affirmed