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Ryan v. Capital Contractors, Inc.

679 F.3d 772 (2012)

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Ryan v. Capital Contractors, Inc.

United States Court of Appeals for the Eighth Circuit

679 F.3d 772 (2012)

Facts

Ron Ryan (plaintiff) worked as a sandblaster for Capital Contractors, Inc. (defendant) until he was terminated in 2008. Ryan had an intelligence quotient of 56, spoke with a stutter, and had difficulty with reading and writing. Troy Collins was the paint-room foreman. Collins worked alongside Ryan and oversaw his day-to-day tasks but had limited authority over his employment. Horseplay and name calling were common at Capital Contractors, but there was a strict no-fighting policy. Collins often called Ryan “fucking dummy,” “fucking retard,” and similar insulting names, and Ryan often called Collins “fatty,” “Shrek,” “giant,” and “bitch.” On November 26, 2008, a verbal and physical altercation ensued between Collins and Ryan that resulted in Ryan striking Collins. Ryan was terminated due to the no-fighting policy. Ryan sued Capital Contractors under the Americans with Disabilities Act, asserting that he was subjected to a hostile working environment. The district court entered summary judgment for Capital Contractors, and Ryan appealed.

Rule of Law

Issue

Holding and Reasoning (Wollman, J.)

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