Walter Wolicki v. PaperWorks Industries, Inc.

Summary

The United States District Court for the Northern District of New York denied PaperWorks Industries, Inc.’s motion to dismiss Walter Wolicki’s amended complaint under Federal Rule of Civil Procedure 12(b)(6). The court held that Wolicki plausibly alleged a disability under the Americans with Disabilities Act and clarified that the amended complaint asserted termination-based disability discrimination claims, not a failure-to-accommodate claim.

Holdings

1. The amended complaint plausibly alleged that Plaintiff had impairments substantially limiting major life activities and therefore adequately alleged a disability under the ADA.
2. Defendant's arguments concerning a failure-to-accommodate claim were moot because Plaintiff did not assert such a claim in the amended complaint.
3. The court could consider the physician medical certification without converting the motion to one for summary judgment because the amended complaint specifically referenced and relied on the document, making it incorporated by reference and integral to the claim.

Questions Presented

1. Whether the amended complaint plausibly alleged that Plaintiff had a disability within the meaning of the ADA.
2. Whether Defendant's arguments concerning failure to accommodate stated a basis for dismissal when Plaintiff had not asserted a failure-to-accommodate claim in the amended complaint.
3. Whether the court could consider a physician medical certification referenced in and integral to the amended complaint without converting the Rule 12(b)(6) motion into one for summary judgment.

Disposition

denied