Knapps v. Education & Training Resources, LLC, et al.

Holding: The Ninth Circuit affirmed in part, vacated in part, and remanded the district court's judgment, dismissing the Rehabilitation Act and one ADA claim while allowing the ADA failure-to-accommodate claim to proceed.
Standard: Federal Rule of Civil Procedure twelve comma six
Vote: The panel unanimously concluded the case was suitable for decision without oral argument.
Practical effect: The case returns to the district court to address the ADA failure-to-accommodate claim and to determine if the administrative charge was timely under the worksharing agreement.

The Ninth Circuit affirmed the dismissal of a Rehabilitation Act claim and an ADA claim against one defendant but vacated the dismissal of an ADA claim against another defendant. The court remanded the case for further proceedings regarding the failure-to-accommodate claim and administrative exhaustion issues.

Background

Uganda Knapps, proceeding pro se, appealed a district court judgment dismissing his workplace disability discrimination claims. The district court had dismissed his claims under the Rehabilitation Act and the Americans with Disabilities Act against two defendants.

The court’s reasoning

The panel reviewed the dismissal de novo under Federal Rule of Civil Procedure twelve comma six. The court found the district court correctly dismissed the Rehabilitation Act claim because Knapps failed to allege facts showing the defendants received federal funding. The court also affirmed the dismissal of the ADA claim against Minact, Inc. because Knapps failed to allege facts showing Minact was his employer. However, the court vacated the dismissal of the ADA claim against Education & Training Resources, LLC. The court found Knapps alleged sufficient facts for a failure-to-accommodate claim regarding his asthma. The court also noted the district court failed to consider whether a worksharing agreement between California and the Equal Employment Opportunity Commission rendered his charge timely for administrative exhaustion purposes.

What it means going forward

The case returns to the district court to address the ADA failure-to-accommodate claim and to determine if the administrative charge was timely under the worksharing agreement.