Harrison v. Department of Veterans Affairs

Holding: The Sixth Circuit affirmed the district court's grant of summary judgment because the appellant forfeited her claims by failing to address the district court's reasoning in her appellate brief.
Standard: Forfeiture of appellate claims
Vote: Unanimous affirmation of summary judgment due to forfeiture of claims.
Practical effect: Employers and lower courts can rely on the forfeiture doctrine to dismiss appeals where appellants fail to specifically rebut the district court's reasoning rather than simply restating their original arguments.

The Sixth Circuit affirmed the district court's grant of summary judgment in favor of the Department of Veterans Affairs. The court held that the appellant forfeited her claims by failing to address the district court's reasoning in her appellate brief.

Background

Plaintiff Latria Harrison sued her former employer, the Department of Veterans Affairs, alleging failure to accommodate, harassment, and retaliation under the Rehabilitation Act and the Family and Medical Leave Act. The district court granted summary judgment in favor of the VA, finding no genuine issues of fact. Harrison appealed, but her brief merely regurgitated her summary judgment briefing without addressing the district court’s specific reasoning.

The court’s reasoning

The court applied the principle that an appellant must successfully challenge the grounds on which the district court relied. The court found that Harrison’s appellate brief failed to address the district court’s reasoning for rejecting her claims regarding accommodation, discrimination, hostile work environment, and retaliation. Because the brief merely regurgitated her pre-decisional briefing, the court deemed the claims forfeited.

merely regurgitat[ing] the brief filed below does not preserve challenges to the district court’s decision

Blick v. Ann Arbor Pub. Sch. Dist., 105 F.4th 868, 873 (6th Cir. 2024)

What it means going forward

Employers and lower courts can rely on the forfeiture doctrine to dismiss appeals where appellants fail to specifically rebut the district court’s reasoning rather than simply restating their original arguments.