Alston v. Park Pleasant, Inc.

Park Pleasant, Inc. (PPI) (defendant) hired Joanie Alston (plaintiff) in August 2011 to be the director of nursing at PPI’s adult-care facility. Alston initially received good performance reviews, but Alston began to clash with a new supervisor in February 2012. On June 26, 2012, Alston missed work for a scheduled biopsy, and on July 12, 2012, Alston was diagnosed with ductal carcinoma in situ (DCIS), also known as intraductal carcinoma or stage-zero breast cancer. Meanwhile, Alston’s performance steadily declined from February 2012 until PPI terminated Alston in August 2012. Alston sued PPI in federal district court, alleging that PPI’s termination constituted discrimination on the bases of age, race, color, and disability. Notably, Alston never alleged at any stage of her district-court proceedings that her DCIS limited a substantial life activity. For example, Alston’s complaint made only passing references to her disability by claiming that PPI’s termination decision occurred within weeks of Alston’s leave for her biopsy and that PPI’s criticisms of Alston increased after PPI became aware of Alston’s serious health issues. Moreover, during her deposition, Alston claimed that she was not substantially limited in any major life activity. The district court granted PPI’s summary-judgment motion and dismissed all of Alston’s claims. Alston appealed only from the district court’s decision to dismiss her claim under the Americans with Disabilities Act (ADA).