Summary
This federal district court opinion addresses a plaintiff's claim against the U.S. General Services Administration alleging wrongful termination in violation of the Rehabilitation Act due to her disability. The court evaluated a Rule 12(b)(6) motion to dismiss, examining whether the plaintiff plausibly alleged she was otherwise qualified for her position and terminated solely because of her disability. Concluding that the amended complaint sufficiently stated a claim despite conflicting deposition testimony, the court denied the defendant's motion to dismiss and allowed the case to proceed.
Topics
Practice areas
Questions Presented
- Whether the plaintiff plausibly alleged a violation of the Rehabilitation Act under the plausibility standard
- Whether the plaintiff satisfied the 'otherwise qualified' and 'disability was the sole reason for termination' elements of the Rehabilitation Act claim
Holdings
- The court held that the plaintiff plausibly stated a claim under the Rehabilitation Act and therefore denied the motion to dismiss.
Factual background
Dickerson, a service‑disabled veteran with multiple disabilities, worked for the GSA in a probationary HR position. After a medical episode that caused slurred speech, her supervisor raised performance concerns and ultimately terminated her, citing performance deficiencies. Dickerson contends she performed the essential functions of her job and that similarly situated non‑disabled employees were not disciplined.
Procedural history
Plaintiff filed a complaint alleging disability discrimination under the Rehabilitation Act. Defendant moved to dismiss the amended complaint for failure to state a claim under Rule 12(b)(6). The court considered the plausibility standard and denied the motion.