Thaddeus M. Lietz v. Procter & Gamble Company

Summary

The United States District Court for the Eastern District of Wisconsin denied Thaddeus M. Lietz’s motion for reconsideration of the order dismissing individual employee defendants from his ADA employment-discrimination action. The court held that 42 U.S.C. § 1981 does not apply to the alleged disability discrimination and that individual employees cannot be held personally liable under the ADA.

Holdings

1. Reconsideration was unwarranted because the plaintiff did not identify a manifest error of law or fact, newly discovered evidence, or a failure to apply controlling precedent.
2. Individual employees cannot be held personally liable under the ADA because they are not employers within the meaning of the statute.

Questions Presented

1. Whether the court committed a manifest error of law or fact by dismissing the individual employee defendants at the initial screening stage.
2. Whether 42 U.S.C. § 1981 or 42 U.S.C. § 1981a authorizes individual employee liability for alleged ADA employment discrimination.

Disposition

other