Goecke v. 3M Company

Background

Richard R. Goecke sued his former employer, 3M Company, alleging disability and religious discrimination under federal and state law. 3M moved for partial judgment on the pleadings under Federal Rule of Civil Procedure 12(c), seeking judgment on the two disability-discrimination counts.

3M argued that Goecke’s Americans with Disabilities Act (ADA) claim should be dismissed because he did not exhaust the required administrative process, that both the ADA and Minnesota Human Rights Act (MHRA) claims were filed too late, and that the complaint did not plausibly allege that 3M regarded him as having a disability.

Court’s Analysis

The court explained that a Rule 12(c) motion uses the same legal standard as a motion to dismiss for failure to state a claim under Rule 12(b)(6). Under that standard, the court accepts well-pleaded facts as true and considers whether they plausibly support relief.

The court dismissed Goecke’s ADA claim for failure to exhaust administrative remedies. Before filing an ADA lawsuit against an employer, a plaintiff generally must identify the disability-discrimination claim in a charge filed with the Equal Employment Opportunity Commission. Goecke’s charge did not check the disability-discrimination box or mention disability discrimination in its description. The court concluded that a disability claim could not reasonably be expected to arise from a charge describing only religious discrimination, even though Goecke was representing himself when he filed the charge.

The court also held that both the ADA and MHRA disability claims were untimely. The parties agreed that the latest alleged discriminatory act occurred on December 1, 2021, when Goecke chose to retire to avoid termination. Because he first raised the disability claims in his December 14, 2022 complaint, the court found that the claims were filed outside the applicable time limits and dismissed both on that basis.

The court did not reach 3M’s argument that Goecke failed to plausibly allege that he was regarded as having a disability. The court noted that, at the hearing, Goecke could not identify authority accepting his argument that unvaccinated status alone can qualify as a perceived disability under the ADA.

Disposition

The court granted 3M Company’s Motion for Partial Judgment on the Pleadings. The order dismissed Goecke’s ADA disability claim for failure to exhaust administrative remedies and dismissed both the ADA and MHRA disability claims as untimely. The order did not state a disposition for the religious-discrimination claims.