Heath Campbell v. Skyward LLC, et al.

Summary

The United States District Court for the Northern District of Alabama denied Defendants’ motion for summary judgment in Heath Campbell’s ADA discrimination action. The court held that a genuine dispute existed regarding whether Skyward LLC had the requisite number of employees under the ADA and whether Skyward and Aqua Systems Alabama LLC should be treated as an integrated enterprise or single employer. The court found evidence relating to interrelated operations, centralized labor relations, common management, and financial control sufficient to allow a reasonable jury to resolve the integrated-enterprise issue.

Holdings

1. Skyward was not entitled to summary judgment because a genuine dispute of material fact existed regarding whether it employed the minimum number of employees required for ADA coverage.
2. Summary judgment was inappropriate for Aqua Systems because evidence concerning interrelation of operations, centralized control of labor relations, common management, and financial control could permit a reasonable jury to find that Skyward and Aqua Systems were an integrated enterprise or single employer.

Questions Presented

1. Whether summary judgment should be denied as to Skyward because a genuine dispute existed regarding whether Skyward employed at least 15 employees for the period required for ADA coverage.
2. Whether sufficient evidence existed for a reasonable jury to find that Skyward and Aqua Systems were an integrated enterprise or single employer under the ADA, allowing their employees to be aggregated for purposes of the ADA's employee-count requirement.

Disposition

other