Kannan v. Apple Inc.

Background

Raja Kannan worked as an engineer for Apple from August 2011 until he transferred to Apple India Pvt. Ltd. in 2018. He claimed Apple discriminated against him in promotions and compensation because Apple perceived him as disabled and because he was associated with his autistic son. He also brought claims under the Americans with Disabilities Act, the California Fair Employment and Housing Act, the Family and Medical Leave Act, and the California Family Rights Act; retaliation claims; and a wrongful-termination claim based on constructive discharge.

Kannan disclosed during an interview that he had an autistic son and would need flexible hours for caregiving and appointments. Apple allowed him to work a flexible schedule. Kannan later claimed that he was denied promotion from the IC4 to IC5 level, did not receive restricted stock units, received unfair performance ratings, and suffered reduced compensation. He also complained internally and filed an administrative discrimination complaint with the California Department of Fair Employment and Housing, which was dual-filed with the Equal Employment Opportunity Commission.

Summary-judgment standard and evidence

The court applied the summary-judgment standard under Federal Rule of Civil Procedure 56. Summary judgment is appropriate when the evidence shows no genuine dispute about a fact important to the result and the moving party is entitled to judgment as a matter of law. The court found that Kannan often disputed Apple’s facts without citing evidence that actually contradicted them, and treated unsupported facts as undisputed for purposes of the motion.

Discrimination claims

The court ruled for Apple on Kannan’s claims that Apple discriminated against him because of his perceived disability or his association with his son. Kannan raised a triable issue about whether he was qualified for an IC5 promotion because his manager, Joseph Kotni, had recommended him. But Apple offered legitimate, nondiscriminatory reasons for denying the promotion: higher management made the final decision, Kannan had less responsibility than the IC5 employees used as comparators, and he needed additional professional development.

The court also concluded that Kannan did not present evidence creating a genuine factual dispute about discriminatory motivation. The employees he identified as comparators had greater responsibility or more management experience. Although denial of a promotion and stock compensation could qualify as adverse employment actions, Kannan did not show that his perceived disability or his son’s disability motivated those decisions. The court therefore granted summary judgment on the disability and associational-disability discrimination claims under the Americans with Disabilities Act and the Fair Employment and Housing Act.

Family and medical leave claims

The court granted summary judgment on Kannan’s Family and Medical Leave Act and California Family Rights Act claims. It found no evidence that Apple denied him leave benefits. His flexible-schedule requests were granted, and there was no evidence that Apple prevented him from attending appointments or denied him any benefit under those laws.

Exhaustion and retaliation claims

Apple argued that Kannan had not exhausted the required administrative remedies for his retaliation claims. The court rejected that argument, concluding that his retaliation and California Family Rights Act allegations were within the scope of, or reasonably related to, an investigation arising from his administrative discrimination complaint.

The court nevertheless granted summary judgment on the retaliation claims. Kannan identified protected activities including requesting a flexible schedule, protesting discrimination, making an internal complaint, and filing administrative complaints. But the court found that Apple had legitimate, non-retaliatory reasons for the promotion and stock-compensation decisions, and that higher management made the final decisions without knowledge of Kannan’s perceived disability or his association with his son. The court also found no evidence connecting any adverse action to Kannan’s schedule requests.

Wrongful termination

The court granted summary judgment on Kannan’s wrongful-termination claim. Kannan argued that he was constructively discharged—that is, that working conditions became so intolerable that a reasonable person would have felt compelled to resign. The court ruled that the alleged failure to promote, denial of stock units, and reduction in compensation were insufficient as a matter of law to establish the unusually severe conditions required for constructive discharge.

Disposition

Judge Edward J. Davila granted Apple’s motion for summary judgment on all thirteen causes of action. The order was filed under seal, and the parties were directed to provide a stipulated redacted version within seven days so the court could issue a public version.

Date note

The supplied case information lists October 19, 2020 as the filing date, while the opinion itself states that it was dated October 13, 2020.