Federal Circuit Upholds SBA’s Size Determination in Obsidian Case

The First Circuit Court of Appeals recently ruled on disability discrimination claims in Der Sarkisian v. Austin Preparatory School, clarifying legal standards under the Americans with Disabilities Act (ADA) and state contract law. The decision, issued in 2023, involved a former employee’s allegations of wrongful termination due to his disability.

Case Background

John Der Sarkisian, a former employee of Austin Preparatory School, sued the school after his employment contract was not renewed. He alleged that the school failed to accommodate his disability and that its decision was unlawfully based on his medical condition. Der Sarkisian argued that his termination violated both the ADA and Massachusetts employment law.

Austin Preparatory School maintained that the decision was based on performance-related concerns, not discrimination. The school further argued that Der Sarkisian failed to engage in the interactive process required under the ADA to determine reasonable accommodations.

Legal Questions Considered

1. Did Austin Preparatory School discriminate against Der Sarkisian based on his disability?
2. Was the school obligated to renew his contract under Massachusetts law?
3. Did the school fail to provide reasonable accommodations under the ADA?

Court’s Decision

The First Circuit ruled in favor of Austin Preparatory School, affirming the lower court’s decision. The court found that:

• The school provided legitimate, non-discriminatory reasons for not renewing Der Sarkisian’s contract, including documented performance concerns.
• Der Sarkisian did not sufficiently demonstrate that the school’s reasoning was pretextual or that his disability was the sole reason for his termination.
• The school engaged in an interactive process but determined that no reasonable accommodation could address the performance-related issues.

Implications for Disability Discrimination Cases

This decision underscores several key takeaways for employers and employees dealing with disability accommodations:

• Employers must engage in an interactive process to determine reasonable accommodations but are not required to renew employment contracts if legitimate reasons exist for non-renewal.
• Employees alleging discrimination must show clear evidence that their termination was directly related to their disability rather than other performance factors.
• Contract law protections may not override employer discretion in cases where performance concerns justify termination.

Legal Support for Social Security Disability and Workplace Rights

Securing Social Security Disability benefits can be complex, and individuals facing workplace discrimination due to a disability may require legal guidance to protect their rights. If you need assistance with a Social Security Disability claim or have concerns about how your disability affects your employment rights, contact us to discuss your case and protect your rights.

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