United States of America, United States District Court for the Northern District of Mississippi, 2 May 2022, Karla D. McKnight v. Renasant Bank

Case overview

Country
United States of America
Case ID
Karla D. McKnight v. Renasant Bank
Decision date
Deciding body (English)
United States District Court for the Northern District of Mississippi
Type of body
Court
Type of Court (material scope)
Civil Court
Type of jurisdiction
Single jurisdiction system
Type of Court (territorial scope)
Local Court
Instance
1st Instance
Area
Industrial relations / Labor law
Further areas addressed
Non-discrimination
Outcome of the decision
Claim inadmissible or rejected
General Summary

Plaintiff was an employee at a bank and was dismissed after receiving negative performance reviews right after his return to work after being hospitalized with Covid-19. Plaintiff filed an action against the bank claiming she suffered prejudice for contracting Covid-19 and that she was disabled because of the consequences of the disease. Defendant filed a motion to dismiss arguing that the five-day hospitalization of the Plaintiff did not qualify as a “record of impairment” under the Americans with Disabilities Act and that the Plaintiff had failed to present a plausible claim. The Court agreed with the Defendant’s arguments and granted the motion to dismiss.

Facts of the case

The Plaintiff worked for the Defendant as a senior payroll assistant. While the Plaintiff was employed by the Defendant, her husband contracted Covid-19; consequently, the Plaintiff was required by the Defendant to take medical leave, effective July 15, 2020. While on medical leave, the Plaintiff contracted Covid-19, and was hospitalized for five days. Due to severe lung problems, she was admitted to the hospital's intensive care unit, where she remained for the full five days. She was treated for Covid-19 and a related case of pneumonia. After receiving a negative Covid-19 test, the Plaintiff returned to work on August 10, 2020. The Plaintiff did not have any complaints about her work performance prior to her medical leave but upon her return, she allegedly began to receive complaints from her immediate supervisor. On August 20, 2020, the Plaintiff received an unsatisfactory performance review, and was discharged on September 9, 2020. She was unable to find subsequent employment for a period of approximately six months.

Type of measure challenged
Private company measure
Individual / collective enforcement
Individual action brought by one or more individuals or legal persons exclusively in their own interest.
Nature of the parties
  • Claimant(s)
    Private individual
  • Defendant(s)
    Private individual
Type of procedure
Ordinary procedures
Reasoning of the deciding body

The Court analyzed the arguments of the Plaintiffs and Defendants and reasoned that:

  1. Impairment is not always considered to be substantially impactful on a major life activity, and an impairment that is not substantially impactful does not satisfy the Americans with Disabilities Act definition of a "disability."
  2. The Plaintiff's five-day case of Covid-19 and pneumonia—after which she tested negative for Covid-19 and after which she suffered no further symptoms, conditions, or effects related to these diseases—were minor and transitory, and therefore fell outside the bounds of the "disability" definition.
Conclusions of the deciding body

The Court concluded that the Defendant had successfully made its case in favor of dismissal and, for that reason, the Defendant's Motion to Dismiss was granted.

Fundamental Right(s) involved
Right to non-discrimination
Fundamental Right(s) instruments (constitutional provisions, international conventions and treaties)
Americans with Disabilities Act
Author of the case note
Maíra Tito, Research Assistant, NOVA School of Law, Lisbon