Der Sarkisian v. Austin Preparatory School, No. 23-1040 (1st Cir. 2023)
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The First Circuit affirmed the decision of the district court granting summary judgment for Defendant on Plaintiff's claims for disability discrimination, in violation of Title I of the Americans with Disabilities Act (ADA) and Mass Gen. Laws ch. 151B, and for age discrimination, in violation of Mass. Gen. Laws ch. 151B, holding that there was no error.
The district court (1) concluded that Plaintiff had failed to carry her burden to make out a prima facie case that she was a "qualified individual" under the ADA and thus also failed to do so under chapter 151B; and (2) concluded that Plaintiff had failed to demonstrate a genuine dispute of material fact as to whether Defendant's proffered reason for her termination was pretextual. The First Circuit affirmed, holding (1) Defendant was entitled to summary judgment on Plaintiff's ADA and Mass. Gen. Laws ch. 151B disability discrimination claims; and (2) the district court did not err in granting summary judgment for Defendant on Plaintiff's claim of age discrimination under Mass. Gen. Laws ch. 151B.
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