Recent Appellate Court Ruling Serves As A RoadMap For Summary Judgment On Fact-Specific Disability Discrimination Cases

Seyfarth Synopsis: While motions for summary judgment are usually tricky to obtain in fact-laden employment cases alleging discrimination, failure to accommodate, and failure to engage in the interactive process, the Court of Appeal recently handed the employer a complete victory when it affirmed summary judgment on all causes of action on just such a case, providing a reminder on the essentials of such claims, as well as a roadmap for employers on achieving dispositive motion victories in such cases.

In Miller v. California Dept. of Corrections and Rehabilitation, 105 Cal. App. 5th 261 (2024), a California Department of Corrections and Rehabilitation ("CDCR") correctional officer who had been placed on an unpaid leave of absence filed suit against the CDCR alleging disability discrimination, failure to accommodate, failure to engage in the interactive process, failure to prevent discrimination, and retaliation. The trial court granted CDCR's motion for