ADA Disability Discrimination Claim Dismissed; No Allegation That Alleged Mistreatment Was Motivated by Plaintiff’s Schizophrenia

From SHANEIS MARDIA GARCIA, Plaintiff, v. KINGS COUNTY HOSPITAL CENTER and MELISSA WALTERS, Defendants., 2018 WL 389212, at *6 (S.D.N.Y., 2018):

Plaintiff’s discrimination claim arising from Walters’ conduct fails because she does not allege that Walters was motivated in any way by her schizophrenia. Throughout her complaint and opposition memorandum, Plaintiff describes numerous times when Walters allegedly treated her unfairly, gave her negative feedback, spoke to her in an abusive and cruel tone, and reprimanded her. See Compl. at 8–29; Pl.’s Opp. at 6–14. She also asserts that Walters’ behavior impacted her physical health, emotional stability, and overall well-being, leaving her unable to work. Compl. at 83, 86. However, she never alleges that Walters mistreated or abused her because she was schizophrenic, and thus fails to allege a prima facie case of ADA discrimination. Whether Plaintiff’s mental illness was exacerbated by Walters’ conduct or other work-related stress is inconsequential to her claim that she suffered discrimination on account of her mental illness. Accordingly, to the extent Plaintiff alleges that Walters’ abusive conduct amounted to discrimination under the ADA, Defendants’ motion to dismiss is GRANTED.

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