Kathy Heisler v. Metropolitan Council

Kathy Heisler v. Metropolitan Council, 17 Am. Disabilities Cas. (BNA) 624 (2003)

Winning Party

Metropolitan Council

Court

Court of Appeals for the Eighth Circuit

Key Issue

Disability Discrimination under the ADA and MHRA

Case Type

CIVIL

Facts

Heisler was hospitalized for six days in January 1999 due to suicidal ideations and was allowed to take medical leave under the Family Medical Leave Act.

Heisler was discharged from her position on July 8, 1999, for being unable to work the required hours.

Kathy Heisler was employed by Metropolitan Council as a Fare Collection Supervisor since 1988.

Heisler suffered adverse employment actions following her requests.

Heisler suffers from major depressive disorder and has been in therapy and on medication for over twenty years.

Heisler engaged in protected activity by requesting accommodation.

Heisler's physician restricted her to day-shift hours due to her condition, which Met Council could not accommodate.

Heisler's claims of limitations in major life activities were not substantiated by sufficient evidence.

Heisler's depression did not prevent her from performing her job duties.

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Key Holdings

Heisler was not considered disabled under the ADA as her major depressive disorder did not substantially limit her major life activities.

The district court erred in dismissing Heisler's retaliation claim as it was not properly raised by Met Council in its summary judgment motion.

Citations

Kathy Heisler v. Metropolitan Council, 17 Am. Disabilities Cas. (BNA) 624, 2003 U.S. App. LEXIS 17580, 339 F.3d 622, 2 A.L.R. Fed. 2d 659, 2003 WL 21805294 (2003)

Legal Reasoning

The court affirmed the district court's ruling on the disability claim, finding that Heisler did not meet the ADA's definition of disability. However, it reversed the dismissal of the retaliation claim, stating that Heisler had adequately pleaded a retaliation claim and that the district court had erred in dismissing it without proper consideration.

Outcome

The district court's judgment is affirmed in part, reversed in part, and remanded for further proceedings consistent with this opinion.

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