Santana

Background

Ray Santana and Brendan Duffy sued the Mount Vernon City School District/Board of Education. Their original complaint asserted claims under the Americans with Disabilities Act (ADA), the Age Discrimination in Employment Act, and New York Executive Law § 296. By the time of this decision, only ADA and New York State Human Rights Law claims remained. The defendants moved for summary judgment under Federal Rule of Civil Procedure 56, which permits judgment without a trial when the evidence shows no genuine dispute about a fact that could affect the result and the moving party is entitled to judgment as a matter of law.

Santana had knee and hip conditions and had been diagnosed with dysthymic disorder. He requested accommodations including no stair climbing, an ergonomic chair, permission to change position and use a cane, placement with students with stable behavior, additional time for reports, voice-to-text assistance, a quiet area during breaks, and supportive staff. The District responded that he could use an elevator, control his own physical movements, receive or obtain some requested items, or that certain requests were not medically related. It also maintained that working with students with varying behavioral needs was an essential part of his special-education position.

Duffy had knee and other injuries and requested ground-floor classrooms at various times. The District sometimes allowed him to work on the ground floor, but it denied a later ground-floor request and directed him to use an elevator. During the coronavirus pandemic, Duffy also sought remote work, a laptop, an internet hotspot, and a mask exemption. The District ultimately denied remote work because teachers were required to return to in-person teaching, while offering personal protective equipment and enhanced cleaning.

Issues Before the Court

The court stated that three categories of claims remained: Santana’s ADA discrimination claims arising after June 5, 2018; Duffy’s ADA discrimination claims concerning accommodation requests in September 2019, 2020, and 2021, excluding pandemic-related requests; and Santana’s ADA and New York State Human Rights Law retaliation claims.

For an ADA failure-to-accommodate claim, a plaintiff had to show that he had a disability, that the employer knew about it, that he could perform the job’s essential functions with a reasonable accommodation, and that the employer refused to provide the accommodation. The court explained that a person is covered as an individual with a disability only if a physical or mental impairment substantially limits one or more major life activities.

ADA Discrimination and Accommodation Claims

The court held that the plaintiffs had not presented enough evidence for a reasonable jury to find that their mobility conditions qualified as ADA disabilities. It ruled that stair climbing was not significant enough to qualify as a major life activity under the ADA. The court also found that Santana and Duffy had not supplied sworn testimony from a medical professional establishing the severity of their mobility limitations. Their own testimony and doctors’ notes were insufficient, in the court’s view, to establish a substantial limitation on a major life activity.

The court separately considered Santana’s dysthymic disorder. Although the evidence supported the existence of a mental impairment, the court found that Santana had not shown which major life activity was impaired or that the impairment substantially limited that activity. The court also noted that a doctor had characterized several requested accommodations as not medically related to Santana’s conditions.

Because the plaintiffs did not establish that they were qualified individuals with disabilities under the ADA, the court held that their failure-to-accommodate claims could not proceed. The court therefore granted summary judgment to the defendants on the ADA discrimination claims.

Retaliation Claims

The court recognized that requesting an accommodation and filing discrimination charges with the New York State Division of Human Rights and the Equal Employment Opportunity Commission were protected activities. It also recognized that filing this lawsuit was protected activity.

The court nevertheless held that Santana had not established a prima facie retaliation case—a basic initial showing required before the claim can proceed. The court found that the denial of accommodation requests, by itself, was not an adverse employment action for purposes of a retaliation claim. As to alleged actions occurring after the lawsuit began, the court found that the claimed adverse actions began about one year after the lawsuit, which was too long a gap to establish a causal connection.

The opinion states that the retaliation framework applied to both ADA and New York State Human Rights Law claims, but its final disposition specifically refers to granting summary judgment on the “ADA retaliation claim.” The conclusion broadly grants the defendants’ motion for summary judgment, directs entry of judgment for the defendants, and orders the case closed.

Disposition

The defendants’ motion for summary judgment was GRANTED. The court directed the clerk to enter judgment in favor of the defendants and close the case.