Noffsinger v. SSC Niantic Operating Co.

273 F. Supp. 3d 326 (2017)

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Noffsinger v. SSC Niantic Operating Co.

United States District Court for the District of Connecticut
273 F. Supp. 3d 326 (2017)

Facts

In 2015, Katelin Noffsinger (plaintiff) was prescribed medical marijuana to treat post-traumatic-stress disorder. Noffsinger registered in Connecticut as a qualifying patient under the Palliative Use of Marijuana Act (PUMA) and began taking Marinol, a synthetic form of cannabis in capsule form. In July 2016, Bride Brook Nursing & Rehabilitation Center (Bride Brook) (defendant) recruited Noffsinger and offered her the position of director of recreational therapy. Noffsinger was required to take a pre-employment drug test, which revealed the presence of marijuana. Noffsinger explained that she was a qualifying medical-marijuana user under PUMA, but Bride Brook rescinded her job offer. Noffsinger brought suit under PUMA, which prohibits discrimination by employers against qualifying medical-marijuana users. Bride Brook filed a motion to dismiss, arguing that PUMA was preempted by federal law, including the Controlled Substances Act (CSA) and the Americans with Disabilities Act (ADA).

Rule of Law

Issue

Holding and Reasoning (Meyer, J.)

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