Dillon Thompson v. Louisville Jefferson County Metro Government

Summary

The United States District Court for the Western District of Kentucky considers Louisville/Jefferson County Metro Government’s motion for summary judgment in Dillon Thompson’s action concerning alleged FMLA interference, labor-contract violations, ADA violations, and punitive damages. The court grants in part and denies in part the motion. The excerpt addresses, among other issues, whether Thompson or his son had an FMLA-qualifying serious health condition and whether Thompson provided sufficient notice of intended FMLA leave.

Holdings

1. Metro was entitled to summary judgment because Thompson failed to establish a prima facie case of FMLA interference. He did not show that he or his son had a qualifying serious health condition, did not provide timely and procedurally compliant notice of the March 10 absence, and did not show denial of an FMLA benefit to which he was entitled.
2. Metro was entitled to summary judgment on the breach-of-contract claim because Thompson did not oppose dismissal.
3. Metro was not entitled to summary judgment on the ADA associational-discrimination claim. Metro's motion addressed a failure-to-accommodate theory rather than the associational-discrimination claim actually pleaded, and Metro therefore waived its arguments directed to the actual claim. In any event, Thompson presented sufficient evidence to create a genuine dispute regarding whether his son's impairments qualified as a disability and whether the elements of associational discrimination could be met.
4. Metro was entitled to summary judgment on Thompson's punitive-damages claim because Thompson presented no evidence that Metro discriminated with malice or reckless indifference to his federally protected rights.

Questions Presented

1. Whether Thompson presented evidence sufficient to establish a prima facie case of FMLA interference, including entitlement to FMLA leave, adequate notice, and denial of FMLA benefits.
2. Whether summary judgment was appropriate on Thompson's breach-of-contract claim where Thompson did not oppose dismissal.
3. Whether Metro was entitled to summary judgment on Thompson's ADA associational-discrimination claim when Metro addressed only a failure-to-accommodate theory in its motion.
4. Whether Thompson presented evidence that Metro acted with the malice or reckless indifference required for ADA punitive damages.

Disposition

other