Maat v. Cnty. of Ottawa
| Decision Date | 06 March 2014 |
| Docket Number | Case No. 1:12-cv-1194 |
| Parties | RENEE MAAT, Plaintiff, v. COUNTY OF OTTAWA and 58TH DISTRICT COURT, Defendants. |
| Court | U.S. District Court — Western District of Michigan |
HON. JANET T. NEFF
Plaintiff Renee Maat filed this disability discrimination action against Defendants Ottawa County and 58th District Court after her request for medical leave was denied and her employment as a court recorder in the 58th District Court was terminated. Pending before the Court are 58th District Court's Motion for Summary Judgment and Motion to Dismiss (Dkt 43) and Defendant Ottawa County's Motion for Summary Disposition (sic, motion to dismiss or motion for summary judgment) (Dkt 47). Plaintiff has filed responses to the respective motions, and Defendants have filed replies. For the reasons set forth in this Opinion, the Court grants 58th District Court's motion. The Court denies Ottawa County's motion to dismiss and denies without prejudice the motion for summary judgment. Having fully considered the parties' written submissions, the Court concludes that oral argument would not assist in the disposition of the issues presented. See W.D. Mich. LCivR 7.2(d) ().
Plaintiff began working at the 58th District Court in 2007 as a traffic clerk and, on December 19, 2008, was promoted to a court recorder position assigned to work in Judge Susan Jonas' courtroom1 (Dkt 49 ¶ 1; Dkt 45 ¶ 2). In November 2010, she was hospitalized for three days for pulmonary embolism and a cerebral vein clot, and subsequently suffered from dizziness, headaches and anxiety attacks (First Am. Compl. (FAC), Dkt 7, ¶¶ 10-12; Pl. Aff., Dkt 53-1, ¶¶ 7-8). In January 2011, Plaintiff began working part-time hours pursuant to her doctor's restrictions; she took leave under the Family Medical Leave Act (FMLA), 28 U.S.C. § 2601 et seq., for the remaining hours (FAC ¶ 11; Dkt 53-1 ¶ 9). Due to her part-time hours, Plaintiff was reassigned to a court clerk position (FAC ¶ 12; Dkt 53-1 ¶ 10).
After her continuing medical problems, in June 2011, a conflict arose over Plaintiff's continued employment and potential short term disability, and she was informed she could not return to work (FAC ¶¶ 13-19). Her employment was terminated as of June 20, 2011 on the grounds that she had exhausted her FMLA leave and her leave of absence would result in an undue hardship (Dkt 45 ¶ 3; FAC ¶¶ 15-19; Dkt 53-1, ¶ 15, Ex. 4).
Plaintiff's FAC alleges three counts: Count 1—Violations of the Rehabilitation Act2 by Defendants Ottawa County and the 58th District Court; Count 2—Violations of the Persons with Disabilities Civil Rights Act3 by Defendants Ottawa County and the 58th District Court; and Count3—Violations of Americans With Disabilities Act4 by Defendant Ottawa County. Each count is premised on Defendants' alleged termination of Plaintiff's employment and denial of a reasonable accommodation based on disability.
In deciding a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim, the court accepts all well-pleaded allegations in the complaint as true and draws all reasonable inferences from those allegations in favor of the nonmoving party. Bennett v. MIS Corp., 607 F.3d 1076, 1091 (6th Cir. 2010); Lambert v. Hartman, 517 F.3d 433, 439 (6th Cir. 2008). "A claim survives this motion where its '[f]actual allegations [are] enough to raise a right to relief above the speculative level on the assumption that all of the complaint's allegations are true.'" Zaluski v. United Am. Healthcare Corp., 527 F.3d 564, 570 (6th Cir. 2008) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 545 (2007)).
Stated differently, the complaint must present "enough facts to state a claim to relief that is plausible on its face." Twombly, 550 U.S. at 570. "The complaint should give the defendant fair notice of what the plaintiff's claim is and the grounds upon which it rests." German Free State of Bavaria v. Toyobo Co, Ltd., 480 F. Supp. 2d 958, 963 (W.D. Mich. 2007); see also Twombly, 550 U.S. at 555 (citing FED. R. CIV. P. 8(a)(2)). Accordingly, the complaint must contain either direct or inferential allegations respecting all the material elements to sustain recovery under a viable legal theory. Bavaria, 480 F. Supp. 2d at 963; see also Lillard v. Shelby Cnty. Bd. of Educ., 76 F. 3d 716, 726 (6th Cir. 1996). Further, "a plaintiff's obligation to provide the 'grounds' of his 'entitle[ment]to relief' requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do ...." Twombly, 550 U.S. at 555.
A moving party is entitled to a grant of its motion for summary judgment "if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law." FED. R. CIV. P. 56(a); see also Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 247-48 (1986). The court must consider the evidence and all reasonable inferences in favor of the nonmoving party. U.S. S.E.C. v. Sierra Brokerage Servs., Inc., 712 F.3d 321, 327 (6th Cir. 2013) (citing Tysinger v. Police Dep't of City of Zanesville, 463 F.3d 569, 572 (6th Cir. 2006)).
The moving party has the initial burden of showing the absence of a genuine issue of material fact. Jakubowski v. Christ Hosp., Inc., 627 F.3d 195, 200 (6th Cir. 2010). The burden then "shifts to the nonmoving party, who must present some 'specific facts showing that there is a genuine issue for trial.'" Id. (quoting Anderson, 477 U.S. at 248). Fuhr v. Hazel Park Sch. Dist., 710 F.3d 668, 673 (6th Cir. 2013) (quoting Tysinger, 463 F.3d at 572). "The ultimate question is 'whether the evidence presents a sufficient disagreement to require submission to a jury or whether it is so one-sided that one party must prevail as a matter of law.'" Back v. Nestlé USA, Inc., 694 F.3d 571, 575 (6th Cir. 2012) (quoting Anderson, 477 U.S. at 251-52).
58th District Court has filed a Motion to Dismiss under FED. R. CIV. P. 12(b)(6) and Motion for Summary Judgment under FED. R. CIV. P. 56, on the ground that Plaintiff's claim under theRehabilitation Act (Count 1) fails because she cannot show the Court is a recipient of federal financial assistance, which is an essential element of her claim.5 58th District Court asserts that the undisputed facts establish that 58th District Court is locally funded by Ottawa County and in 2011, the year relevant to this case, did not receive federal funds directly from the federal government or indirectly through Ottawa County or the State Court Administrative Office (SCAO). Further, if Plaintiff's federal claim under the Rehabilitation Act is dismissed, this Court should decline supplemental jurisdiction over the PWDCRA state law claim, and it should be dismissed pursuant to FED. R. CIV. P. 12(b)(1).
An essential element of a claim under § 504 of the Rehabilitation Act of 1973 is that the relevant program or activity is receiving federal financial assistance. Sandison v. Mich. High Sch. Athletic Ass'n, Inc., 64 F.3d 1026, 1030-31 (6th Cir. 1995). Section 504 of the Rehabilitation Act provides in relevant part:
No otherwise qualified individual with a disability in the United States, as defined in section 705(20) of this title, shall, solely by reason of her or his disability, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance ....
"Program or activity" is further defined as "all of the operations of":
Plaintiff does not dispute 58th District Court's evidence that it did not directly receive federal funding in 2011. In this regard, 58th District Court has presented affidavits stating that in 2011 no federal funds received by Ottawa County were expended for 58th District Court operations, and the Court did not receive any federal funds from the SCAO, as a grantee from any federal agency, as a subgrantee of Ottawa County, or as a subgrantee through the State of Michigan.6
Plaintiff nonetheless argues that 58th District Court is part of the larger "State district court" that was extended federal financial assistance in 2011, and if any part of a department receives financial assistance, the whole department is deemed a recipient of federal assistance (Dkt 54 at 8-9). Further, a state entity is not required to receive federal assistance; "extending" such funding is sufficient (id. at 14). That is, the mere availability of federal grant funds from the SCAO constituted "extending" federal financial assistance to 58th District Court, even though 58th District Court was not one of the local district courts that received the grant funds. Plaintiff thus argues that there can be no dispute that federal financial assistance was "indirectly extended" to 58th District Court under the language of § 794(b)(1) (id. at 15).
Plaintiff's reasoning is vulnerable at several junctures and does not support a conclusion that 58th District Court was an indirect recipient of federal financial assistance. While...
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