Posted: April 24th, 2023

Essay

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ASBBS PROCEEDINGS OF THE 23RD ANNUAL CONFERENCE

AMERICANS WITH DISABILITY ACT (ADA) AND

ASSOCIATIONAL DISCRIMINATION: POLICY AND

PRACTICE ISSUES FOR EMPLOYERS

Calvasina, Gerald E.

Southern Utah University

calvasina@suu.edu

Calvasina, Richard V.

University of West Florida

rcalvasi@uwf.edu

Calvasina, Eugene J.

Southern University

ejcalvasina@cox.net

ABSTRACT The associational discrimination provision of the Americans with Disability Act (ADA) prohibits

employment discrimination against applicants and employees, whether or not they have a

disability, because of their known relationship or association with a person with a known

disability. The stated purpose of this provision; “is to prevent employers from taking adverse

actions based on unfounded stereotypes and assumptions about individuals who associate with

people who have disabilities” (EEOC, 2011). In addition to federal law, a number of states and

local governments have also enacted statutory protection for employees regarding associational

discrimination. Over the last ten years, the number of charges alleging violation of the association

provisions received by the Equal Employment Opportunity Commission (EEOC), with the

exception of FY 2012, has steadily increased. Employees have also had increased success in

substantiating allegations regarding associational discrimination (HR Hero, 2008). The purpose

of this paper is to examine recent litigation associated with the associational discrimination

provisions of the ADA and state laws. In addition, policy and practice suggestions are presented

to help employers minimize the risks associated with allegations regarding associational

discrimination.

INTRODUCTION

The associational discrimination provision of the Americans with Disability Act (ADA) prohibits

employment discrimination against applicants and employees, whether or not they have a

disability, because of their known relationship or association with a person with a known disability.

The stated purpose of this provision; “is to prevent employers from taking adverse actions based

on unfounded stereotypes and assumptions about individuals who associate with people who have

disabilities” (EEOC, 2011). Over the last ten years, the number of charges alleging violation of

the association provisions received by the Equal Employment Opportunity Commission (EEOC),

with the exception of FY 2012, has steadily increased (Table 1).

mailto:calvasina@suu.edu
mailto:rcalvasi@uwf.edu
mailto:ejcalvasina@cox.net
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Table 1: Relationship/Association Charges

FY

2005

FY

2006

FY

2007

FY

2008

FY

2009

FY

2010

FY

2011

FY

2012

FY

2013

FY

2014

184 194 253 303 326 444 482 425 518 537

Source: EEOC (2015) ADA Charge Data.

Monetary benefits obtained for individuals associated with relationship/association complaints by

the EEOC also increased from 2005 when $465,164 was obtained to 2014 when $1,470,427 was

obtained. The total for 2014 however was a sharp decline from the two previous years when

$2,244,357 was obtained in 2012 and $1,954,636 was awarded in 2013 (Table 2).

Table 2: Monetary Benefits ($)

FY

2005

FY

2006

FY

2007

FY

2008

FY

2009

FY

2010

FY

2011

FY

2012

FY

2013

FY

2014

465,16

4

466,02

8

579,29

6

533,87

5

995,50

9

1,088,7

20

1,287,6

89

2,244,3

57

1,954,6

36

1,470,4

27

Source: EEOC (2015) ADA Charge Data.

A number of states and local governments also have enacted statutory protection regarding

associational discrimination. Section 12926 of the California Fair Employment and Housing Act

(FEHA) has a prohibition against discrimination on the basis of physical disability. It “includes a

perception that the person has any of those characteristics or that the person is associated with a

person who has, or is perceived to have, any of those characteristics” (Rope v. Auto-Chlor, 2013).

On July 16, 2015, an amendment to the California FEHA was signed into law by the governor that

extended protection from retaliation to workers who request an accommodation to aid someone

they are associated with (Ochoa, 2015). This amendment was fueled by the California appeals

court decision in Rope v. Auto-Chlor case where the court ruled the employee was not protected

from retaliation for requesting accommodation to aid his disabled sister’s medical condition

(Ochoa, 2015).

Employees have also had increased success in substantiating allegations regarding associational

discrimination (HR Hero, 2008). The potential for success is enhanced by the ability of plaintiffs

to proceed with their initial allegations of associational discrimination. In order to proceed,

plaintiffs need to establish that the employer was “aware that an employee’s relative had a

disability” (HR Hero, 2008). For example, in a “close-knit workplace, it isn’t uncommon for

employees to know about the health conditions of their coworkers’ families. How many of us have

signed a “get-well” card for a coworker’s ill family member?” (HR Hero, 2008). The purpose of

this paper is to examine recent litigation associated with the association provision of the ADA and

policy and practice suggestions for employers to minimize the risk associated with allegations

regarding violations.

WHAT IS ASSOCIATIONAL DISCRIMINATION? Title I of the Americans with Disability Act (ADA) makes it unlawful for private sector employers

and state and local government employers with 15 or more employees to discriminate against

qualified applicants or employees because of a disability in any aspect of employment. State

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statutes can extend protection to employees of smaller employees, as with the California FEHA

that applies to employers with 5 or more employees.

The “association” provision of the ADA also protects applicants and employees from

discrimination based on their relationship or association with an individual with a disability,

whether or not the applicant or employee has a disability (EEOC, 2011). The ADA does not

require a family relationship for an individual to be protected by the association provision, and the

“key is whether the employer is motivated by the individual’s relationship or association with a

person who has a disability” (EEOC, 2011). The EEOC guidance on association provision

provides a detailed example as to how close the association or relationship with a person with a

disability has to be for an individual to be protected by the association provision (Exhibit 1).

Exhibit 1: How close does the association or relationship with a person with a disability have to

be for an individual to be protected by the association provision?

Example A: An employer overhears an employee mention to a co-worker that he tutors

children at a local homeless shelter. The employer, recalling that the shelter in question is well-

known for providing job placement Helpance for people living with HIV/AIDS, terminates the

employee because it believes that its image will be tarnished if its employees associate with the

“kind of person” who contracts HIV/AIDS. The employer has violated the ADA’s association

provision even if the employee is only minimally acquainted with beneficiaries of the shelter

who have HIV/AIDS, because it made an adverse employment decision based on concerns about

the disabilities of people with whom the employee has an association.

Source: EEOC, (2011). Questions and Answers about the Association Provision of the Americans

with Disabilities Act

The EEOC guidance also provides numerous examples as to the types of employer conduct

prohibited by the association provision (Exhibit 2).

Exhibit 2: What types of employer conduct does the association provision prohibit?

An employer may not terminate or refuse to hire someone due to that person’s known

association with an individual with a disability.

Example B: An employer is interviewing applicants for a computer programmer position. The

employer determines that one of the applicants, Arnold, is the best qualified, but is reluctant to

offer him the position because Arnold disclosed during the interview that he has a child with a

disability. The employer violates the ADA if it refuses to hire Arnold based on its belief that

his need to care for his child will have a negative impact on his work attendance or performance.

Example C: A restaurant owner discovers that the chef’s boyfriend is HIV-positive. The

owner, fearing that the employee will contract the disease and transmit it to the customers

through food, terminates the employee. This is a violation of the ADA’s association provision.

An employer may not deny an employee who has an association with a person with a

disability a promotion or other opportunities for advancement due to that association.

Example D: Tiffany, a part-time salesperson at a large appliance store, applies for a full-time

position. The manager hiring for the position rejects Tiffany’s application because, having heard

that Tiffany’s mother and sister had breast cancer, he concludes that Tiffany is likely to acquire

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the same condition and be unable to reliably work the hours required of a full-time

salesperson. This is a violation of the association provision of the ADA.

An employer may not make any other adverse employment decision about an applicant

or employee due to that person’s association with a person with a disability.

Example E: The president of a small company learns that his administrative Helpant, Sandra,

has a son with an intellectual disability. The president is uncomfortable around people with this

type of disability and decides to transfer Sandra to a position in which he will have less contact

with her to avoid any discussions about, or interactions with, Sandra’s son. He transfers her to

a vacant entry-level position in the mailroom which pays less than Sandra’s present position, but

will allow him to avoid interacting with her. This is a violation of the ADA’s association

provision.

An employer may not deny an employee health care coverage available to others because

of the disability of someone with whom the employee has a relationship or association.

Example F: An employer who provides health insurance to the dependents of its employees

learns that Jaime, an applicant for a management position, has a spouse with a disability. The

employer determines that providing insurance to Jaime’s spouse will lead to increased health

insurance costs. The employer violates the ADA if it decides not to hire Jaime based on the

increased health insurance costs that will be caused by his wife’s disability.

Example G: In the previous example, it would also violate the ADA for the employer to offer

Jaime the position without the benefit of health insurance for his dependents. The employer

may not reduce the level of health insurance benefits it offers Jaime because his wife has a

disability; nor may it subject Jaime to different terms or conditions of insurance.

An employer may not deny an employee any other benefits or privileges of employment

that are available to others because of the disability of someone with whom the employee

has a relationship or association.

Example H: A company has an annual holiday party for the children of its employees. The

company president learns that one of its newly hired employees, Ruth, has a daughter with Down

Syndrome. Worried that Ruth’s daughter will frighten the other children or make people

uncomfortable, he tells Ruth that she may not bring her daughter to the party. Ruth has been

denied the benefits and privileges of employment available to other employees due to her

association with a person with a disability.

An employer may not subject someone to harassment based on that person’s association

with a person with a disability. An employer must also ensure that other employees do

not harass the individual based on this association.

Example I: Martin and his supervisor, Adam, have had an excellent working relationship, but

Adam’s behavior toward Martin has changed since Adam learned that Martin’s wife has a severe

disability. Although Martin has always been a good performer, Adam repeatedly expresses his

concern that Martin will not be able to satisfy the demands of his job due to his need to care for

his wife. Adam has begun to set unrealistic time frames for projects assigned to Martin and yells

at Martin in front of co-workers about the need to meet approaching deadlines. Adam also

recently began requiring Martin to follow company policies that other employees are not

required to follow, such as requesting leave at least a week in advance. Adam has removed

Martin from team projects, stating that Martin’s co-workers do not think that Martin can be

counted on to complete his share of the work “considering all of his wife’s medical

problems.” Though Martin has complained several times to upper management about Adam’s

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behavior, the employer does nothing. The employer is liable for harassment on the basis of

Martin’s association with an individual with a disability.

Source: EEOC (2011). Questions and Answers about the Association Provision of the Americans

with Disabilities Act.

While these examples are not absolute examples of guilt or innocence, they are indicative of the

types of situations that will certainly capture the attention of the EEOC when complainants bring

these situations to their attention.

The Association provision also prohibits retaliation by an employer against anyone who opposes

discriminatory employment practices, files a charge of employment discrimination, or testifies or

participates in any way in an investigation, proceeding, or litigation regarding associational

discrimination. An important aspect of the ADA that is not available to plaintiffs under the

association provision is the availability of reasonable accommodation. Under the ADA, only a

qualified applicant or employee with a disability is entitled to reasonable accommodation.

According to the EEOC guidance, for example, an employer would not be required to modify its

leave policy for an employee who needs time off to care for a child with a disability (EEOC, 2011).

RECENT LITIGATION

In Buffington v. PEC Management (d/b/a Burger King), Theresa Buffington was employed by

PEC in a restaurant management capacity from December of 2003 until November 2010

(Buffington v. PEC Management, 2014). Buffington also had a son who succumbed to a 12 year

battle with cancer in June of 2011. PEC managers knew of Buffington’s son’s condition before or

as of the time of her employment with PEC (Buffington v. PEC Management, 2014). On

November 12, 2010, Buffington was terminated for violating company policy for allowing a non-

management employee to drive for company business on November 7, 2010 and for “ongoing

issues related to performance” (Buffington v. PEC Management, 2014). In a deposition given by

one of the managers involved in the termination, the manager stated “the rule violation …was that

straw that broke the camel’s back, and because of that rule violation, I had to let her go”

(Buffington v. PEC Management, 2014). It was also alleged that the same manager made

statements at the termination meeting such as, “We need someone whose head is there 100

percent,” “We are planning on spending 400 grand to remodel the restaurant,” “Now you can go

spend all your time with your son,” and “Please go spend some time with your son” ([ECF No. 36

at 5-6], Buffington v. PEC Management, 2014). Buffington successfully challenged PEC

Management’s arguments regarding her performance by convincing the jury that she was never

documented for “Poor Work Performance” ([ECF No 36 at 83] Buffington v. PEC Management,

2014). Buffington was also able to convince the jury that the company had not consistently

enforced its use of vehicles policy (Buffington v. PEC Management 2014). In denying PEC’s

request to set aside the jury verdict and award, the court noted that the creditability of statements

made by PEC’s manager at the termination meeting was for the jury to decide and, the company’s

argument that those statements were nothing more than “performance critique and a compassionate

“off-the-record” statement made while parting ways” were not enough to set aside the verdict

(Buffington v. PEC Management, 2014). The jury awarded Buffington $115,000 in front pay

damages, $70,000 in compensatory damages, and back pay damages of $43,156.06.

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Three other United States District Court cases, in Tennessee, Massachusetts, and New York saw

employers’ motions for summary discharge of employee lawsuits rejected. In Covington v.

Vanderbilt Mortgage and Finance, Inc., Patricia Covington was hired as a mailroom clerk in 2002

and eventually promoted to an account representative for the company in 2003. She also had a

disabled daughter. In October of 2009, Mrs. Covington’s daughter suffered a “psychotic break”

and was subsequently admitted to a hospital for treatment (Covington v. Vanderbilt Mortgage and

Finance, Inc., 2015). Mrs. Covington received Family and Medical Leave Act (FMLA) leave on

an intermittent basis to care for her daughter who was diagnosed with schizophrenia and

depression (Covington v. Vanderbilt Mortgage and Finance, Inc., 2015). In April of 2010, Mrs.

Covington was also approved for personal leave to deal with a personal medical condition. Mrs.

Covington’s doctor indicated in certifications to extend her intermittent leave to care for her

daughter, that “the probable duration of leave required would be lifelong… to care for daughter”

(Covington v. Vanderbilt Mortgage and Finance, Inc., 2015). Covington subsequently submitted

request for additional personal leave for additional personal surgery in July of 2011.

Throughout Covington’s career with her employer, she had received good Assessments, and for

eight of her nine years with the company, was ranked as a “consistent performer” who had “future

position possibilities” (Covington v. Vanderbilt Mortgage and Finance, Inc., 2015). She received

annual raises in 2007, 2008, 2009 in addition to a merit raise in 2010. In November of 2011 she

received her first “unacceptable” in meeting assigned goals and a month later was counseled for

delinquencies in her customer account bucket (Covington v. Vanderbilt Mortgage and Finance,

Inc., 2015). In January of 2012 Covington underwent surgery on her wrist and fearing loss of her

job, continued to work rather than take two weeks of FMLA leave. She was terminated on

February 1, 2012 allegedly for not meeting her performance goals in 9 of the previous 12 months

(Covington v. Vanderbilt Mortgage and Finance, Inc., 2015). In denying the company’s motion

to summarily dismiss the lawsuit, the court noted in particular, the remarks made by decision

makers involved in Covington’s dismissal. Those remarks included remarks by her direct

supervisor that she was missing too much time from work and was being distracted from her work

because of her daughter (Covington v. Vanderbilt Mortgage and Finance, Inc., 2015). The court

also noted that while the company had alleged that Covington had missed performance goals

because of her absences, that a male employee who also missed his performance goals over a

comparable period of time was not dismissed in part because supervisors utilized other employee

to help the male employee meet his performance goals (Covington v. Vanderbilt Mortgage and

Finance, Inc., 2015).

In Fenn v. Mansfield Bank, Ryan Fenn was employed as a Systems Administrator for Mansfield

Bank from May 2013 to April 21 of 2014 (Fenn v. Mansfield Bank, 2015). Subsequent to his

termination on April 21, 2014, Fenn had informed his manager that his wife suffered from lupus,

Raynaud’s disease and rheumatoid arthritis (Fenn v. Mansfield Bank, 2015). In May of 2014,

Fenn was notified that he had to attend a one week training session in Burlington, Massachusetts.

At that time, he informed his manager that traveling to the training would create a hardship due to

his need to care for his wife (Fenn v. Mansfield Bank, 2015). He asked his manager “repeatedly”

if there were other options for the training and, his request eventually led to the April 21, 2014

meeting with his manager, the human resources manager and the bank’s IT manager (Fenn v.

Mansfield Bank, 2015). At the meeting, Fenn again requested to take the training closer to his

home or online and at the end of the meeting was told by the human resources manager that “before

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making any final decision they would meet again the following day after considering plaintiff’s

request overnight” (Fenn v. Mansfield Bank, 2015). Rather than waiting overnight, Fenn was

terminated before the end of the day. In its request to dismiss the lawsuit, the bank contended that

the ADA does not require employers to provide reasonable accommodation to an employee who

is not himself handicapped to allow an employee to take care of a disabled family member (Fenn

v. Mansfield Bank, 2015). In this case, the court notes that the employee is not claiming he was

fired because of his request for an accommodation but that the determining factor in the “abrupt

decision to terminate him” was that the defendant’s animosity against him for even asking for the

accommodation (Fenn v. Mansfield Bank, 2015). In the decision, the court noted that had the bank

reconvened the meeting the next day and denied Fenn’s request for an accommodation, that the

bank would have been within its legal rights to terminate him (Fenn v. Mansfield Bank, 2015). At

this stage of the proceedings though, Fenn did have enough to establish a prima facie case of

associational discrimination under the ADA. He will ultimately have to establish “conclusively

that defendant based its termination decision upon some sort of animosity or prejudice towards

plaintiff’s disabled spouse” (Fenn v. Mansfield Bank, 2015).

In Manon v. 878 Education, Elizabeth Manon, was employed as a receptionist in the admissions

department of 878 Education, LLC from May through November of 2012. She was also the mother

of an infant child that was ultimately diagnosed with Reactive Airway disease (Manon v. 878

Education, 2015). During the time that Manon worked at 878 Education, she was frequently absent

due to a variety of medical issues associated with her daughter that included emergency trips to

the hospital. The record indicates that the Manon left work early 54 times, arrived late 27 times

and was absence 17 days. There was also evidence that she had worked past her scheduled eight

hours per day on more than 31 occasions (Manon v. 878 Education, 2015). The record also

indicated that Manon had informed her supervisor regarding her daughter’s October 10, 2012,

emergency room visit and that her supervisor responded to her “not to worry about her absence

from work” (Manon v. 878 Education, 2015). After additional trips to the emergency room in

November, when Manon returned to work on November 16, she was fired by her supervisor. At

the November 16, 2012 meeting where Manon was terminated, the supervisor told Manon he was

“letting her go because he needed someone without children to work at the front desk” and that he

needed “someone who does not have kids who can be at the front desk at all times” (Manon v. 878

Education, 2015). The supervisor also asked Manon “how can you guarantee me that two weeks

from now your daughter is not going to be sick again? So what is it, your job or your daughter?”

(Manon v. 878 Education, 2015). According to the court, these statements were viewed as

“smoking gun” admission that the supervisor believed that Manon’s daughter was disabled and

would be frequently ill and that the termination of Manon was directly motivated by the

supervisor’s hostility towards her association with her daughter (Danaher, 2015).

SUMMARY AND RECOMMENDATIONS FOR EMPLOYERS In three of the four cases cited in this paper, statements attributed to either immediate supervisors

or other managers involved in the termination decision of the employees were cited by the courts

as supportive of the employees’ allegations regarding the employers’ motivation to terminate. In

Fenn, while the court did not cite the type of statements utilized in the other cases, the court did

cite the decision to terminate Fenn after the human resource manager told him they would meet

with the employee after considering his request overnight (Fenn v. Mansfield Bank, 2015). The

ADA is often described as being part of the “Bermuda Triangle of Employment Law” that includes

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the ADA, the Family Medical Leave Act (FMLA) and Workers Compensation regulations. The

interaction among these three statutes has created legal mind fields for employers for a number of

years, and despite the number of court decisions over time that have attempted to guide employers

compliance efforts, we still see the type of evidence utilized in the aforementioned cases creating

legal dilemmas for employers. A consistent recommendation from courts over the years regarding

employer efforts to comply with the legal requirements to provide work environments where

employees can work free from discrimination and harassment admonishes employers to provide

supervisors and managers with up-to-date effective training. Given the volume of federal and state

regulation regarding the general duty that virtually all employers have to provide work places that

are free of discrimination, including harassment that is no easy task. Yet, training that is a must.

Canned off the shelf programs that cut cost but do not give decision makers what they need to

navigate the legal mind fields will not suffice. Additionally, far too many organizations do not

effectively evaluate the effectiveness of their training. Good training is expensive but unless

organizations assess the effectiveness of their training efforts the attempt to mitigate the negative

consequences associated with their legal compliance efforts will be in vain. In the Buffington

case, there were a number of “common errors” in addition to comments regarding Buffington’s

need to care for her son. (Ferrara, Fiorenza, Larrison, Barrett & Reitz, 2015). Common errors

identified by Ferrara and associates include problems with Buffington’s performance Assessment,

inconsistent enforcement of company policies, and the proverbial lack of documentation (Ferrara,

Fiorenza, Larrison, Barrett & Reitz, 2015). Lack of documentation for performance problems and

inconsistent application of policy have been consistently identified as impediments to employers

attempting to defend their termination decisions when those decisions come under legal scrutiny.

CONCLUSIONS The volume of regulation at the federal and state level of human resource decision making

continues to grow and increase in complexity. This ever expanding growth in the breadth and

depth of the regulation of human resource decision making further complicates the dilemma for

employers regarding how much to spend on efforts to mitigate their exposure to litigation

regarding discrimination allegations. Good faith effort strategies still seem to carry weight with

regulators so efforts to foster compliance via extensive training and Assessment of decision makers

still appears to be the most prudent course to follow. To do it right will not be cheap, but given

the stakes, to do nothing or the minimum will simply not suffice.

REFERENCES

Buffington v. PEC Management, (2014), Theresa Buffington v. PEC Management II, LLP d/b/a

Burger King, Civ. No. 1:11-cv-229 Erie, United States District court for the Western

District of Pennsylvania.

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Covington v. Vanderbilt Mortgage and Finance, Inc., (2015), Patricia A. Covington v. Vanderbilt

Mortgage and finance, Inc., No.: 3:13-CV-250-PLR-CCS, United States District court

Eastern district of Tennessee at Knoxville.

Danaher, Maria, (2015). Supervisor’s alleged remark regarding sick child precludes dismissal of

ADA associational claim, downloaded 5/27/2015 from

http://www.employmentlawmatters.net/2015/03/articles/ada/supervisors-alleged-remark-

regarding-sick-child-precludes-dismissal-of-ada-associational-claim/ .

EEOC, (2011). Questions and Answers about the Association Provision of the Americans with

Disabilities Act, downloaded 5/8/2015 from

http://www.eeoc.gov/facts/association_ada.html .

EEOC, (2015). ADA Charge Data, downloaded 5/18/2015 from

http://www.eeoc.gov/eeoc/statistics/enforcement/ada-receipts.cfm

Fenn v. Mansfield Bank, (2015), Ryan Fenn v Mansfield Bank, Civil Action No. 14-12554-NMG,

United States District Court District of Massachusetts.

Ferrara, Fiorenza, Larrison, Barrett & Reitz, (2015). Jury Awards $200K+ to employee Claiming

ADA Discrimination Based on “Association” with Disabled Son: A Cautionary Tale for

all Employers, downloaded 5/18/2015 from

http://www.ferrarafirm.com/articles_clips/ADA2.aspx

HR Hero, (2008). Association discrimination: New Lawsuit Trent, downloaded 5/8/2015 from

http://blogs.hrhero.com/diversity/2008/10/20/association-discrimination-new-trend-in-

employee-claims/ .

Manon v. 878 Education, (2015). Elizabeth Manon v. 878 Education, LLC, Alfonso Garcia, and

Alex Oliner, United States District Court Southern District of New York, No. 13-cv-3476.

Ochoa, Lizbeth, (2015). Calif.: Employees Requesting Accommodation Are now protected,

downloaded 7/28/2015 from

http://www.shrm.org/legalissues/stateandlocalresources/pages/calif-accommodation-

protected.aspx?utm_source=HR%20Week%20July%2027%202015%20(1)&utm_mediu

m=email&utm_content=July%2028,%202015&MID=00212906&LN=Calvasina&spMail

ingID=23142763&spUserID=ODM1OTIzOTI5OTES1&spJobID=602767051&spReport

Id=NjAyNzY3MDUxS0 .

Rope v. Auto-Chlor, (2013). Scott Rope v. Auto-Chlor System of Washington, Inc., Court of

Appeal, Second District, Division 1, California, B242003, downloaded 5/21/15 from

http://caselaw.findlaw.com/ca-court-of-appeal/1646966.html .

Supervisor’s alleged remark regarding sick child precludes dismissal of ADA associational claim.

Supervisor’s alleged remark regarding sick child precludes dismissal of ADA associational claim.

http://www.eeoc.gov/facts/association_ada.html
http://www.eeoc.gov/eeoc/statistics/enforcement/ada-receipts.cfm
http://www.ferrarafirm.com/articles_clips/ADA2.aspx
http://blogs.hrhero.com/diversity/2008/10/20/association-discrimination-new-trend-in-employee-claims/
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http://www.shrm.org/legalissues/stateandlocalresources/pages/calif-accommodation-protected.aspx?utm_source=HR%20Week%20July%2027%202015%20(1)&utm_medium=email&utm_content=July%2028,%202015&MID=00212906&LN=Calvasina&spMailingID=23142763&spUserID=ODM1OTIzOTI5OTES1&spJobID=602767051&spReportId=NjAyNzY3MDUxS0
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http://www.shrm.org/legalissues/stateandlocalresources/pages/calif-accommodation-protected.aspx?utm_source=HR%20Week%20July%2027%202015%20(1)&utm_medium=email&utm_content=July%2028,%202015&MID=00212906&LN=Calvasina&spMailingID=23142763&spUserID=ODM1OTIzOTI5OTES1&spJobID=602767051&spReportId=NjAyNzY3MDUxS0
http://www.shrm.org/legalissues/stateandlocalresources/pages/calif-accommodation-protected.aspx?utm_source=HR%20Week%20July%2027%202015%20(1)&utm_medium=email&utm_content=July%2028,%202015&MID=00212906&LN=Calvasina&spMailingID=23142763&spUserID=ODM1OTIzOTI5OTES1&spJobID=602767051&spReportId=NjAyNzY3MDUxS0
http://www.shrm.org/legalissues/stateandlocalresources/pages/calif-accommodation-protected.aspx?utm_source=HR%20Week%20July%2027%202015%20(1)&utm_medium=email&utm_content=July%2028,%202015&MID=00212906&LN=Calvasina&spMailingID=23142763&spUserID=ODM1OTIzOTI5OTES1&spJobID=602767051&spReportId=NjAyNzY3MDUxS0
http://caselaw.findlaw.com/ca-court-of-appeal/1646966.html
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