Smith v. Clark County School District

Reconsideration of an order denying summary judgment is proper when a district court commits clear error as it does when it fails to apply Supreme Court precedent; when deciding if someone is a “qualified individual” under the ADA, a district court must use the standards set forth in Cleveland v. Policy Mgmt. Sys. Corp. for evaluating inconsistent statements made on benefit and disability applications; if a party offers sufficient explanations for inconsistent statements made on benefit applications that is enough for their claim to succeed past the summary judgment stage.

Jacqlyn Smith brought this lawsuit against the Clark County School District (the "school district") for violating the Americans with Disability Act (“ADA”) and not providing reasonable accommodations. From 2004 to 2008 Smith worked as an elementary school teacher for the school district. In 2001, Smith hurt her back and that led her to pursue a less physically demanding job with the school district. Smith worked as a literary specialist from 2004 to 2008. In 2008 the school district asked Smith to begin teaching kindergarten again. Smith objected and, unable to come to an agreement, applied for Family Medical Leave (“FMLA”) and disability benefits. The Ninth Circuit held that the district court did not abuse its discretion in reconsidering the order denying summary judgment because a district court can properly reconsider an order when clear error has been made and the district court committed clear error when it failed to apply Supreme Court precedent. The panel also held that the district court erred when determining whether Smith was a “qualified individual” under the ADA because it did not properly use the framework set forth by the Supreme Court in Cleveland v. Policy Mgmt. Sys. Corp., when analyzing inconsistent statements made on benefit applications. Finally, the court held that the district court erred in granting summary judgment because Smith had offered sufficient explanations for her inconsistent statements in her disability and benefit applications. AFFIRMED in part; REVERSED in part.