Milteer v. Navarro County, No. 23-10872 (5th Cir. 2024)
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Rick Milteer, a disabled veteran and an observant African American Messianic Jewish believer, was employed by Navarro County, Texas, in its Texoma High Intensity Drug Trafficking Area (HIDTA) division as an Information Technology (IT) manager. Milteer alleged that he faced discrimination, retaliation, and failure to accommodate in violation of Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act of 1990, and the Texas Commission on Human Rights Act. His claims were based on his supervisor's refusal to allow him to work remotely while recovering from surgery and during the Covid-19 pandemic, and his subsequent suspension and termination after he discovered a data breach and reported it.
The district court granted summary judgment in favor of Navarro County, dismissing all of Milteer's claims. The court found that Navarro County was Milteer's employer and that the County had provided a legitimate, non-discriminatory reason for terminating Milteer's employment. The court also found that Milteer had failed to produce any evidence that he had informed the County of his disabilities or requested an accommodation from the County.
The United States Court of Appeals for the Fifth Circuit vacated the district court's judgment and remanded the case for further proceedings. The appellate court found that the district court erred in treating Navarro County and the Texoma HIDTA as separate entities and in failing to impute the actions of Milteer's supervisor to the County. The court held that the Texoma HIDTA was not a legal entity capable of employing individuals, and that the actions and inactions of Milteer's supervisor could be imputed to the County. The court concluded that this error impacted the district court's analysis of Milteer's claims, necessitating a remand for further proceedings.
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