Brouillard v. Sunrun, Inc.

Summary

The Appellate Division, Second Department affirmed an order addressing claims brought by Luke Brouillard against Sunrun, Inc. arising from the rescission of a job offer after a positive marijuana test. The court held that the complaint failed to state a disability-discrimination claim under the New York State Human Rights Law because it did not allege that the plaintiff could perform the job’s essential functions with reasonable accommodation, but sufficiently stated claims under the broader New York City Human Rights Law.

Holdings

1. The complaint failed to state a cause of action under the NYSHRL because it did not allege facts sufficient to show that, with reasonable accommodations, Brouillard could perform the essential functions of the job.
2. The complaint sufficiently stated NYCHRL disability-discrimination claims because it alleged that Brouillard was disabled and was discriminated against based on his disability.

Questions Presented

1. Whether Brouillard stated a cause of action for disability discrimination under the New York State Human Rights Law.
2. Whether Brouillard stated a cause of action for disability discrimination under the New York City Human Rights Law based on Sunrun's refusal to hire him after a positive marijuana test despite knowledge that he used medical marijuana to treat a medical condition.

Disposition

affirmed