Pressley v. Management Support Technology, Inc.

Summary

The United States District Court for the District of Columbia denied the plaintiff’s partial motion for summary judgment and granted the defendant’s cross-motion for summary judgment in an employment discrimination case. The plaintiff alleged disability discrimination, failure to accommodate, retaliation, and interference under the ADA, DCHRA, FMLA, and DCFMLA. The court concluded that the evidence showed the plaintiff could not perform the essential function of timely, on-site attendance even after schedule adjustments, and that his termination was based on alleged security violations rather than unlawful discrimination or retaliation.

Holdings

1. Pressley was not a qualified individual under the ADA because he could not consistently perform the essential function of timely, reliable, on-site attendance, even after MSTI adjusted his schedule to accommodate a later start time.
2. MSTI was entitled to summary judgment on Pressley's ADA and DCHRA failure-to-accommodate and disability-discrimination claims because Pressley failed to establish that he was a qualified individual.
3. MSTI was entitled to summary judgment on Pressley's ADA and DCHRA retaliation claims concerning his suspensions and denial of a professional-development opportunity because Pressley failed to present sufficient evidence that MSTI's stated performance-based reasons were pretextual.
4. MSTI was entitled to summary judgment on Pressley's retaliation claims because the record showed a legitimate, nonretaliatory reason for termination—MSTI's reasonable belief that Pressley violated FTC security protocols—and Pressley failed to show that reason was pretextual.
5. MSTI was entitled to summary judgment on Pressley's FMLA and DCFMLA interference claims because he did not show that MSTI interfered with or prejudiced the exercise of his leave rights.

Questions Presented

1. Whether Pressley was a qualified individual under the ADA capable of performing the essential functions of his position with or without reasonable accommodation.
2. Whether MSTI was entitled to summary judgment on Pressley's ADA and DCHRA failure-to-accommodate and disability-discrimination claims.
3. Whether Pressley presented sufficient evidence that MSTI's suspensions and denial of a professional-development opportunity were retaliation for protected accommodation activity under the ADA and DCHRA.
4. Whether Pressley presented sufficient evidence that MSTI's termination was retaliation for requesting ADA accommodations or FMLA and DCFMLA leave.
5. Whether MSTI interfered with Pressley's FMLA or DCFMLA rights by delaying approval of leave or requiring substitution of paid leave.

Disposition

other