Mackey v. Utah Military Academy

Summary

The United States District Court for the District of Utah grants Utah Military Academy’s motion for summary judgment in Stuart Mackey’s action alleging disability discrimination and failure to accommodate under the Americans with Disabilities Act. The court concludes that Mackey failed to establish an ADA-qualifying disability, that he was regarded as disabled, that he was qualified to perform the essential functions of his position, or that he requested an accommodation based on a disability. The court also finds no evidence that the stated reason for his termination was pretextual.

Holdings

1. Mackey failed to establish an actual impairment because he offered only a PTSD diagnosis and limited lay testimony, without medical evidence or expert testimony showing that PTSD substantially limited a major life activity.
2. Mackey failed to establish a record of impairment because his alleged limitation concerned working with one supervisor rather than a broad class of jobs or a broad limitation on the major life activity of working.
3. Mackey failed to establish that UMA regarded him as disabled because the decisionmaker, Schino, did not know of his PTSD, and the evidence concerning Superintendent Orris did not show awareness of a qualifying, nontransitory, nonminor impairment.
4. Mackey failed to show that he was qualified to perform the essential functions of his job, with or without reasonable accommodation.
5. Mackey failed to present affirmative evidence that his alleged disability was a determining factor in his termination.
6. Mackey failed to establish a failure-to-accommodate claim because he did not inform UMA of a disability and resulting limitations or request an accommodation based on those limitations.
7. UMA was entitled to summary judgment because Mackey failed to establish a prima facie case of ADA discrimination or failure to accommodate.

Questions Presented

1. Whether Mackey established that he had a disability under the ADA through an actual impairment, a record of impairment, or being regarded as impaired.
2. Whether Mackey was qualified to perform the essential functions of his military-instructor position, with or without reasonable accommodation.
3. Whether Mackey presented evidence that UMA terminated him because of his alleged disability.
4. Whether Mackey requested a reasonable accommodation based on a disclosed disability and resulting limitations.
5. Whether UMA was entitled to summary judgment on Mackey's ADA discrimination and failure-to-accommodate claims.

Disposition

other