Kenneth Wilson v. TK Elevators Corporation

Summary

The document is a memorandum opinion and order addressing TK Elevator Corporation’s motion for summary judgment in Kenneth Wilson’s claims for disability discrimination under the Americans with Disabilities Act and Iowa Civil Rights Act, and age discrimination under the Iowa Civil Rights Act. The court discusses summary-judgment standards, evidentiary objections concerning witness state of mind, the plaintiff’s alleged disability based on obesity, and the employer’s stated performance and safety concerns.

Holdings

1. Wilson failed to establish that he had an actual or perceived disability because he presented no evidence that his obesity resulted from an underlying physiological disorder or that TK Elevator perceived a specific qualifying impairment.
2. TK Elevator was entitled to summary judgment on the disability-discrimination claims because Wilson failed to establish the disability element and, alternatively, failed to present sufficient evidence that the employer's performance-based reason for termination was pretext for disability discrimination.
3. Wilson failed to present evidence from which a reasonable jury could conclude that age played a part in his termination.
4. The court could consider sworn deposition testimony concerning witnesses' states of mind because Wilson did not contend that the testimony was inadmissible and failed to produce evidence creating a genuine dispute.

Questions Presented

1. Whether Wilson presented sufficient evidence that he had an actual or perceived disability under the ADA or ICRA, including whether his obesity resulted from an underlying physiological disorder.
2. Whether Wilson presented sufficient evidence that TK Elevator's stated performance-related reason for termination was pretext for disability discrimination.
3. Whether Wilson presented sufficient evidence that age played a part in his termination under the ICRA.
4. Whether defendant was entitled to summary judgment on all claims.

Disposition

dismissed