control. It asserted that these connections justified treating Modern Group and Dragon Rig as a single entity under the law. Id. at *18. Ultimately, the court found that the EEOC had established that the Modern Group and Dragon Rig indeed operated as an integrated enterprise, and therefore denied the defendants’ motion for summary judgment on that issue. Next, on the issue of whether Dare qualified as having a disability under the ADA, the EEOC argued that Dale’s opioid use disorder and anxiety significantly impaired his brain function and other major life activities so as to evidence a qualified disability. Modern Group argued that Dare could not demonstrate an actual disability, and referenced his testimony and medical records that they asserted showed no substantial limitations. Modern Group contended that Dare’s conditions were managed with medication and that he had no formal diagnosis of learning disabilities or functional disorders. In contrast, the EEOC asserted that Dare’s untreated anxiety severely impacted his ability to function in daily life, affecting his concentration, communication, and work. The court determined that when assessing whether an impairment is a disability, the effects of any mitigating measures, like medication, should not be considered. Therefore, the court reasoned any evaluation must focus on how Dare’s conditions would affect him without medication. Despite Modern Group’s arguments, the court found that genuine disputes of material fact remained regarding the extent of Dare’s impairments and whether they substantially limited his major life activities. Id. at *47-48. Consequently, the court ruled that the determination of Dare’s disability status under the ADA should be left for further examination by a trier of fact. Id. at *48. The court granted the EEOC’s summary judgment motion on several affirmative defenses that Dragon Rig either abandoned or failed to properly plead in its response, including a failure to state a claim defense. Accordingly, the court granted in part and denied in part the parties’ cross-motions for summary judgment. In EEOC v. Princess Martha, LLC , 2024 U.S. Dist. LEXIS 174147 (M.D. Fla. Sept. 26, 2024), the EEOC filed an action on behalf of charging party, Sarah Branyan (Branyan), against the defendants, Princess Martha, LLC, TJM Property Management, Inc., and TJM Properties, Inc. The EEOC alleged that the defendants unlawfully discriminated against Branyan by failing to hire or accommodate her due to her disability, Post Traumatic Stress Disorder (PTSD), under the ADA. Specifically, the defendants allegedly rescinded a job offer to Branyan after she disclosed that she takes prescription medications to treat her PTSD. Id. at *20. Branyan applied for a position at Princess Martha, a retirement community in St. Petersburg, Florida. Following an interview, she was directed to take a drug test as the final step in the hiring process, with the understanding that she would be hired if she passed. Branyan took her drug test, which yielded a “non-negative” result, and the sample was subsequently lost in the mail, never reaching the lab for further testing. Despite Branyan’s attempts to clarify her medication situation with Princess Martha, she received a rejection notification a week later. The EEOC brought the instant action and the parties filed cross-motions for summary judgment, which the court granted in part and denied in part. The defendants argued that Branyan’s PTSD did not significantly impair her functioning, that she was not a qualified candidate due to her incomplete drug testing, and that the defendants were unaware of her disability at the time of the decision. Additionally, the defendants contended that Branyan never made a request for accommodation. The court acknowledged that there was enough evidence for a reasonable jury to conclude that Branyan was disabled, given her substantial limitations in major life activities due to PTSD. However, the court found that the EEOC failed to provide evidence that Branyan was not hired specifically because of her disability. Regarding her status as a qualified individual under the ADA, the court noted that while Branyan might not have received a drug test result – an essential requirement for the job – this was due to an external issue ( i.e., the sample being lost in transit) rather than her inability to comply. Id. at *21-22. Thus, a reasonable jury could find that she was qualified. The court also held that although Branyan claimed she disclosed her PTSD during the interview, it was unclear whether the decision-maker had actual knowledge of this information. Ultimately, the court ruled that without actual knowledge of Branyan’s disability, there could be no causal link established for the alleged discrimination. Id. at *25. Therefore, the court granted summary judgment in favor of the defendants on the basis that the EEOC did not meet the burden of proving a prima facie case of discrimination. The court in EEOC v. Defender Association Of Philadelphia, 2024 U.S. Dist. LEXIS 155251 (E.D. Penn. Aug. 29, 2024), denied summary judgment for both parties on the central claims in the lawsuit, which involved the EEOC’s allegation that Defender Association of Philadelphia (DAP), a legal services organization, terminated an attorney who requested additional medical leave. The EEOC filed an action on behalf of charging party M.P., a former staff attorney who contended that DAP failed to provide reasonable accommodations for her disabilities and wrongfully terminated her employment in violation of the ADA. The parties filed cross-motions for summary
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EEOC Litigation Review - 2025
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