Luckadue v. North Little Rock School District

IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF ARKANSAS
CENTRAL DIVISION
LAURA LUCKADUE 	PLAINTIFF
CASE NO. 4:24-CV-00533-BSM
NORTH LITTLE ROCK SCHOOL DISTRICT 	DEFENDANT
ORDER
The North Little Rock School District’s motion for summary judgment [Doc. No. 10]
is granted and Laura Luckadue’s complaint is dismissed with prejudice.
I. BACKGROUND
According to the District’s statement of undisputed facts (SUMF), Doc. No. 12, and
Luckadue’s response (Resp.), Doc. No. 20, the undisputed facts are as follows.
Luckadue was a child nutrition assistant for the District until 2024, when her contract
was not renewed. SUMF ¶ 1. Before her contract was not renewed, Luckadue had been
suspended for five days, and her shift was changed from the morning shift to the afternoon
shift. Resp. ¶¶ 3 and 16. Luckadue argues that the District suspended her, changed her shift,
and failed to renew her contract because she requested reasonable accommodations for a
disability and because she filed charges of discrimination against the District. Resp. ¶¶ 1–3
and 10–14. The District, however, argues that it suspended Luckadue, changed her shift, and
decided not to renew her contract because of her disciplinary issues. 	SUMF ¶¶ 2–8 and
49–55. 	Luckadue is suing for discrimination and retaliation under the Americans with
Disabilities Act, and common law constructive discharge. 	The District is moving for
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summary judgment.
II. LEGAL STANDARD
Summary judgment is appropriate when there is no genuine dispute as to any material
fact, and the moving party is entitled to judgment as a matter of law. See Fed. R. Civ. P.
56(a); Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249–50 (1986). Once the moving party
demonstrates that there is no genuine dispute of material fact, the non-moving party may not
rest upon the mere allegations or denials in her pleadings. Holden v. Hirner, 663 F.3d 336,
340 (8th Cir. 2011). 	Instead, the non-moving party must produce admissible evidence
demonstrating a genuine factual dispute requiring a trial. Id. All reasonable inferences must
be drawn in a light most favorable to the non-moving party. Holland v. Sam’s Club, 487
F.3d 641, 643 (8th Cir. 2007). 	The evidence is not weighed, and no credibility
determinations are made. Jenkins v. Winter, 540 F.3d 742, 750 (8th Cir. 2008).
III. DISCUSSION
A. 	ADA
Summary judgment is granted on Luckadue’s ADA retaliation and failure-to-
accommodate-claims.
1. Retaliation
Luckadue argues the District retaliated against her by (1) failing to renew her contract
when she filed charges of discrimination and requested accommodations for her disabilities,
and (2) suspending her for requesting accommodations for her disabilities.
Luckadue does not present direct evidence of retaliation, so she must show that
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retaliation can be inferred from the District’s actions. McDonnell Douglas Corp. v. Green,
411 U.S. 792, 802 (1973); Gilbert v. Des Moines Area Cmty. Coll., 495 F.3d 906, 917 (8th
Cir. 2007). 	To do so, Luckadue must first establish a prima facie case of retaliation by
showing that (1) she engaged in statutorily protected activity; (2) she suffered an adverse
employment action; and (3) a causal connection between the two. See Oehmke v. Medtronic,
Inc., 844 F.3d 748, 758 (8th Cir. 2016). If she does this, the burden shifts to the District to
provide a legitimate, non-retaliatory reason for the adverse employment action. See Mitchell
v. Iowa Prot. & Advocacy Servs., Inc., 325 F.3d 1011, 1013 (8th Cir. 2003). If the District
meets this burden, the burden shifts back to Luckadue to show that the reasons provided by
the District are merely pretext for discrimination. Id.
Summary judgment is granted on Luckadue’s claim that the District failed to renew
her contract because she filed charges of discrimination against it. 	Although Luckadue
engaged in protected activity when she filed charges of discrimination against the District
and she suffered an adverse employment action when the District declined to renew her
contract, there is nothing in the record showing that these events are related. 	Indeed,
Luckadue testified that she does not believe the District failed to renew her contract because
of her EEOC charges. See Luckadue Dep., 265:6–11, Doc. No. 10, Ex. A.
Even if Luckadue presented a prima facie case, the District provided legitimate, non-
discriminatory reasons for not renewing her contract. The District has produced Luckadue’s
attendance and disciplinary records, which show that Luckadue (1) was consistently
disrespectful, unprofessional, and insubordinate in the workplace, (2) failed to fulfill her job
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duties, (3) was regularly tardy for her shifts; and that (4) between July 2021 and April 2023,
she was absent from work a total of ninety-seven days. See Def.’s Br. Supp. Mot. Summ. J.
at 1–2 and 18–20. And, Luckadue has failed to show that these reasons are pretext.
Summary judgment is also granted on Luckadue’s claim that the District failed to
renew her contract because she requested an accommodation, because she fails to establish
a prima facie case. 	This is true because Luckadue does not show that her request for an
accommodation and the non-renewal of contract are related. Luckadue testified that she did
not believe the District’s failure to renew her contract was because of her request for an
accommodation. See Luckadue Dep., 264:24–265:5. Rather, Luckadue admits the District’s
decision to not renew her contract was based on her workplace misconduct and disciplinary
history. 	Id.
Even if Luckadue established a prima facie case, the District provided non-
discriminatory reasons for not to renewing her contract. Again, the District produced records
showing that Luckadue was repeatedly disciplined for workplace misconduct and that she
never returned to work after her suspension, and Luckadue presented no evidence showing
the District’s reasons are pretext.
Finally, summary judgment is granted on Luckadue’s claim that the District suspended
her in retaliation for requesting an accomodation because she has failed to make out a prima
facie case. Here too, Luckadue fails to show that the District’s decision to suspend her was
related to her request for an accommodation. First, Luckadue testified that she believes she
was suspended because the District believed she hit a co-worker with a trash can—not
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because she requested an accomodation. 	See Luckadue Dep., 264:13–16. 	Second, the
District has provided evidence showing that the decision to suspend Luckadue was made
before she requested accommodations. 	See Def.’s Br. Supp. Mot. Summ. J. at 13–14.
Accordingly, Luckadue has failed to establish a prima facie case.
Even if Luckadue established a prima facie case, the District provided legitimate,
non-discriminatory reasons for suspending her. The District produced records showing that
Luckadue was suspended because of her tardiness, hitting another staff member with a trash
can, shoulder bumping the same staff member, and defying protocol and the chain of
command. See Def.’s Br. Supp. Mot. Summ. J. at 13–14; see also Twymon v. Wells Fargo
& Co., 462 F.3d 925, 935 (8th Cir. 2006) (“We have consistently held that violating a
company policy is a legitimate, non-discriminatory reason for terminating an employee.”).
Luckadue fails to show these reasons are pretext.
2. Failure to Accommodate
Summary 	judgment 	is 	granted 	on 	Luckadue’s 	failure-to-accommodate 	claim.
Luckadue argues that the District’s refusal to move her to the morning shift after she
informed the scheduling director that her vertigo prevented her from working the afternoon
shift was a failure to provide a reasonable accomodation. See Luckadue Dep. at 159:2–23.
To state a failure-to-accommodate claim, Luckadue “must establish both a prima facie case
of discrimination based on disability and a failure to accommodate it.” Shaffhauser v. United
Parcel Serv., Inc., 794 F.3d 899, 905 (8th Cir. 2015). 	To state a prima facie case of
discrimination, Luckadue must show that (1) she was disabled as defined by the ADA; (2)
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she was qualified to perform the essential functions of the job; and (3) she suffered an
adverse employment action because of her disability. See Higgins v. Union Pac. R.R. Co.,
931 F.3d 664, 669 (8th Cir. 2019). If Luckadue establishes a prima facie case, the District
must present a legitimate, nondiscriminatory reason for its actions. 	McDonnell Douglas
Corp., 411 U.S. at 802. 	If the district meets its burden, Luckadue must show that the
district’s reason is merely pretext for discrimination. Id.
Summary judgment is granted on Luckadue’s failure to accommodate claim because
Luckadue is not a qualified individual with a disability, and therefore, she cannot establish
a prima facie case. See Peyton v. Fred’s Stores of Ark., Inc., 561 F.3d 900, 903 (8th Cir.
2009) (“a person who cannot perform any of the functions of the job, with or without a
reasonable accommodation, cannot, as a matter of law, be considered ‘otherwise qualified’
under the ADA”). Maintaining cooperative and respectful working relationships was one of
the functions of Luckadue’s job, and the record indicates that Luckadue was repeatedly
disciplined and hit a co-worker with a trash can. See Def.’s Br. Supp. Mot. Summ. J., Exs.
4, 10–13, 16, 19, 22–26; Walz v. Ameriprise Fin., Inc., 779 F.3d 842, 845 (8th Cir. 2015) (the
ability to work with others may be a job-related requirement). 	Luckadue also repeatedly
failed to show up for work. See Id. at Ex. 15; Lipp v. Cargill Meat Sols. Corp., 911 F.3d 537,
544 (8th Cir. 2001) (“An employee who is unable to come to work on a regular basis is
unable to satisfy any of the functions of the job in question, much less the essential ones.”)
(cleaned up).
Even if Luckadue established a prima facie case, the District has offered legitimate,
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non-discriminatory reasons for denying her transfer requests, and she has failed to show
pretext. 	The record shows that the District was unable to transfer Luckadue back to the
morning shift at her original job site because doing so would have led to more disruptive
interactions and physical altercations between Luckadue and other employees on the morning
shift. See Def.’s Br. Supp. Mot. Summ. J., 12–13. Indeed, Luckadue was transferred from
the morning shift to the afternoon shift because of her altercations with other co-workers.
See Jacob Smith Dep. at 43:2–44:25, Doc. No. 10. Further, the District shows that, although
it considered transferring Luckadue to the morning shift at a different location, this was not
possible because doing so would have led to overstaffing and potential disruptions with other
employees. 	See Id.; Peebles v. Potter, 354 F.3d 761, 766 (8th Cir. 2004) (reasonable
accommodation cannot impose undue burden on the employer). 	Although Luckadue
contends these reasons are pretext, nothing in the record supports this contention.
C. 	Constructive Discharge
Summary judgment is granted on Luckadue’s constructive discharge claim because,
even if she exhausted this claim, there is no evidence that the District committed acts so that
Luckadue would quit her job. To establish a claim of constructive discharge, Luckadue must
show (1) that a reasonable person in her situation would find her working conditions
intolerable, and (2) that the District intended her to quit. See Rester v. Stephens Media, LLC,
739 F.3d 1127, 1132 (8th Cir. 2014). 	Nothing indicates that the District intended for
Luckadue to quit. On the contrary, the record shows that the District made numerous efforts
to retain Luckadue by putting her on performance improvement plans, issuing her warnings,
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moving her to a different shift, and suspending her, rather than firing her. 	See Br. Supp.
Def.’s Mot. Summ. J., Exs. 4, 10, 12, 13, 16, 19, 22, 26, 34. All of the evidence points to the
fact that Luckadue voluntarily resigned.
IV. CONCLUSION
For these reasons, the District’s motion for summary judgment is granted and
Luckadue’s complaint is dismissed with prejudice.
IT IS SO ORDERED this 15th day of December, 2025.
_________________________________
UNITED STATES DISTRICT JUDGE
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