Summary
The United States Court of Appeals for the Third Circuit reviews summary judgment in Jeffrey Steidle’s ADA and FMLA retaliation claims against his former employer, United States Liability Insurance Co., Inc. The court holds that the Burlington Northern materially adverse action standard applies to ADA and FMLA retaliation claims and that lower-than-anticipated bonuses and salary increases may qualify as adverse employment actions. It affirms summary judgment concerning the 2021 compensation decisions, vacates summary judgment concerning the 2020 decisions, and remands for consideration of pretext.
Topics
Practice areas
Questions Presented
- Whether lower-than-anticipated bonuses and salary increases can constitute adverse employment actions for retaliation claims under the ADA and FMLA.
- Whether Steidle established a causal connection between his protected activity and the lower 2020 bonus and salary increase.
- Whether Steidle established a causal connection between his 2021 accommodation request and the lower 2021 bonus and salary increase.
- Whether the case should be remanded for the District Court to consider pretext as to the 2020 retaliation claims.
Holdings
- The Burlington Northern materially adverse-action standard applicable to Title VII retaliation claims also applies to retaliation claims under the ADA and the FMLA. An action is materially adverse if it might have dissuaded a reasonable worker from making or supporting a charge of discrimination or exercising statutory rights.
- Steidle established a prima facie case of ADA and FMLA retaliation based on the lower 2020 bonus and salary increase, including adverse action and causation.
- Steidle failed to establish causation for his ADA retaliation claim based on the lower 2021 bonus and salary increase.
- The case must be remanded for the District Court to consider in the first instance whether USLI's reasons for the 2020 compensation decisions were pretextual.
Key quotations
“Today, we hold that it does.” (13-14)
“We now join our sister circuits and hold that the Supreme Court’s formulation of an adverse employment action under Title VII applies to retaliation claims under the ADA and the FMLA as well.” (16-17)
“Receipt of a lower than anticipated bonus and salary increase could certainly dissuade a reasonable worker from engaging in protected activity.” (19-20)
Factual background
Steidle, who had major depressive disorder, PTSD, and anxiety, worked for USLI and generally received annual bonuses and salary increases. After informing supervisors of his mental-health struggles, taking FMLA leave, and requesting ADA accommodations, he received substantially lower bonuses and salary increases in 2020 and 2021 than in prior years. He later took additional medical leave, requested accommodations, did not return to work, and was terminated after his physician could not provide a foreseeable return date.
Procedural history
Steidle sued USLI after his employment was terminated, asserting disability discrimination under the ADA and retaliation under the ADA and FMLA. The District Court granted USLI summary judgment on all claims, concluding that Steidle had not established a prima facie case because he had not shown an adverse employment action or causation. The Third Circuit affirmed as to the 2021 bonus and salary-increase claims, vacated as to the 2020 bonus and salary-increase retaliation claims, and remanded for consideration of pretext.
Remand instructions
Vacate the grant of summary judgment on Steidle's retaliation claims arising from the 2020 bonus and salary increase, and remand for the District Court to consider in the first instance whether Steidle can establish pretext. Affirm the grant of summary judgment on the retaliation claims arising from the 2021 bonus and salary increase.