Judge William Jay Riley wrote that Judy Libel, a former
manager for Adventure Lands of America in Iowa,
couldn’t prove a connection between increased health
insurance premiums and her firing in 2002. Libel was fired
the day after the company learned about an increase in its
health premiums, which Libel claimed raised the issue of
discrimination under the ADA or the Employee Retirement
Income Security Act (ERISA).
Riley further asserted that there was no evidence that Matthew Krantz, the general manager who fired Libel, had any knowledge at the time he fired her that the premiums would be increasing from $10,173 per month to $13,799 a month.
Libel began working in 1997 for Adventure Lands, which owns and operates an amusement park, a campground, and a hotel/convention center. Shortly after was hired, she was diagnosed with multiple sclerosis, but continued to work. John Krantz was Adventure Lands’s chief executive and his son, Matthew Krantz, became the hotel’s general manager in September 2002.
According to the opinion, Matthew Krantz said Libel often made mistakes that included failing to request menus in a timely fashion, overbooking the hotel, and giving away rooms for free. He fired Libel in 2002, and during that conversation, there was no mention of Libel’s medical condition or health insurance benefits.
The day before Libel was fired, the Adventure Lands’ health care provider told the company’s controller that they were hiking the premiums – a fact that was not shared with Matthew Krantz at the time. Libel claimed that in a post-termination conversation on November 14, John Krantz allegedly told her about the rise in health insurance premiums and said that he could not afford health insurance for both Libel and himself. John Krantz had cancer. However, he later denied that the conversation even took place.
Libel sued in federal court, claiming disability discrimination under ADA and interference with prospective insurance benefits under ERISA. After finding that Matthew Krantz was the sole decisionmaker regarding Libel’s discharge and that she failed to establish a case under ADA, ERISA, or state law, the district court granted summary judgment to Adventure Lands. Libel appealed to the 8th Circuit.
However, the appeals court rejected Libel’s request for
a summary judgment and on the grounds that her firing was
linked to the increase in premiums. Riley wrote that
“Libel presented no direct evidence of
discrimination,” and that the record doesn’t show that
“John Krantz terminated Libel, used Matthew Krantz as
a conduit to terminate Libel, or discussed any insurance
cost-cutting matters or Libel’s M.S. condition with Matthew
In her appeal , Libel didn’t challenge the district court’s finding that Libel failed to prove she has an ADA- qualifying disability, nor did she challenge the district court’s finding that she could not perform the essential functions of her job, with or without a reasonable accommodation.
For the full opinion go here .
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