John Hertig v. Butler University

Summary

The United States District Court for the Southern District of Indiana granted Butler University's Rule 12(b)(6) motion to dismiss claims brought by John Hertig under the Americans with Disabilities Act, Section 504 of the Rehabilitation Act, and state contract law. The court held that Hertig plausibly alleged a disability but failed to plausibly allege that his termination was caused by his disability or constituted retaliation for protected activity. The federal claims were dismissed without prejudice with leave to amend, and the court declined supplemental jurisdiction over the breach-of-contract claim.

Holdings

1. Hertig plausibly alleged a legally cognizable disability because his generalized anxiety disorder could reasonably be inferred to be an episodic impairment that substantially limits major life activities when active, notwithstanding treatment.
2. Hertig failed to plausibly allege that Butler University's termination was connected to or caused by his disability.
3. Hertig failed to plausibly allege a causal link between protected activity and his termination, so his ADA retaliation claim was dismissed.
4. The court declined to exercise supplemental jurisdiction over the remaining state-law breach-of-contract claim after dismissing all claims over which it had original jurisdiction.
5. Hertig was granted leave to amend because he had not previously amended his complaint and amendment was appropriate at this stage.

Questions Presented

1. Whether Hertig plausibly alleged a disability under the ADA and Rehabilitation Act.
2. Whether Hertig plausibly alleged that Butler University's termination was caused by his disability, including under the Rehabilitation Act's more stringent causation standard.
3. Whether Hertig plausibly alleged an ADA retaliation claim based on the timing and circumstances of his termination.
4. Whether the court should exercise supplemental jurisdiction over the state-law breach-of-contract claim after dismissing all federal claims.
5. Whether Hertig should receive leave to amend his complaint.

Disposition

other