Phillips v. Hennepin County

Background

Ronald L. Phillips sued Hennepin County and the City of St. Louis Park. His complaint alleged violations of Title II of the Americans with Disabilities Act (ADA) and a claim for “loss of public stature.” He described interactions involving a statement that he was Jewish, a question about how to spell “Hannaka,” and a statement by an unnamed Hennepin County employee that, “You are not tall, I thought you would be tall.” Phillips sought a $50,000 settlement and $7,000,000 for “loss of public stature.”

The defendants filed motions to dismiss under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not allege enough facts to state a legally plausible claim.

ADA claim

The court explained that an ADA claim requires facts showing that the plaintiff has a qualified disability, was excluded from or denied the benefits of a government service or program, or was otherwise discriminated against, and that the exclusion or discrimination occurred because of the disability.

The court held that Phillips’s statement, “I am a Jew,” did not establish that he had an ADA-qualified disability. The court also found no factual allegations connecting any denial of services to a qualified disability and no factual allegations showing intentional disability discrimination. The court therefore concluded that Phillips had not plausibly stated an ADA discrimination claim.

Defamation claim

The court addressed Phillips’s “loss of public stature” allegation as a defamation claim under Minnesota law. It explained that such a claim requires a false and defamatory statement about the plaintiff, publication of that statement to a third party without privilege, and harm to the plaintiff’s reputation in the community.

The court found that Phillips did not allege facts showing that the defendants made false and defamatory statements about him, published such statements to a third party, or caused reputational harm through their statements. The court also found that the alleged comment about his height, without additional supporting facts, did not adequately plead either intentional disability discrimination or defamation.

Additional materials

Phillips submitted additional materials in response to the motions, including a thank-you note, news clippings, photographs, identification cards, a letter, and a “Hurt Feelings Report” form. The court found that he did not explain how those materials factually demonstrated an ADA violation or defamation.

Disposition

The court concluded that the complaint did not plausibly support either the ADA claim or the defamation claim. Judge Wilhelmina M. Wright granted Hennepin County’s and the City of St. Louis Park’s motions to dismiss and ordered that judgment be entered accordingly.