Adam Bogart v. Univ. of Ky.

CourtCourt of Appeals for the Sixth Circuit
DecidedMarch 18, 2019
Docket18-5029
StatusUnpublished

This text of Adam Bogart v. Univ. of Ky. (Adam Bogart v. Univ. of Ky.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Adam Bogart v. Univ. of Ky., (6th Cir. 2019).

Opinion

NOT RECOMMENDED FOR FULL-TEXT PUBLICATION File Name: 19a0129n.06

No. 18-5029

UNITED STATES COURT OF APPEALS FILED FOR THE SIXTH CIRCUIT Mar 18, 2019 DEBORAH S. HUNT, Clerk ADAM BOGART, ) ) Plaintiff-Appellant, ) ON APPEAL FROM THE ) UNITED STATES DISTRICT v. ) COURT FOR THE EASTERN ) DISTRICT OF KENTUCKY UNIVERSITY OF KENTUCKY, ) ) Defendant-Appellee. )

Before: KEITH, COOK, and LARSEN, Circuit Judges.

LARSEN, Circuit Judge. Adam Bogart, a former lab technician at the University of

Kentucky, claims that the University violated the Kentucky Whistleblower Act and the Kentucky

Civil Rights Act when it terminated him. According to Bogart, he was fired for telling his

supervisor that statistical data she purchased from an outside company was seriously flawed.

Bogart also alleges the University fired him because he has Tourette syndrome. The district court

granted the University’s motion to dismiss the Whistleblower Act claim after concluding that

Bogart’s complaint to his supervisor was not protected activity under that statute. The district

court then granted summary judgment for the University on the disability discrimination claim

because Bogart failed to make out a prima facie case of discrimination and, alternatively, failed to

create a genuine issue of material fact regarding whether the University’s asserted reason for firing

him—his unsatisfactory performance—was pretextual. Bogart now appeals the district court’s

disposition of both claims. For the following reasons, we AFFIRM. No. 18-5029, Bogart v. Univ. of Ky.

I.

Bogart suffers from Tourette syndrome “complicated by dystonia and mild cognitive

impairment that is triggered by stress.” His symptoms include slight incoordination, head shaking,

eye blinking, and, occasionally, grunting. Bogart also experiences some symptoms of obsessive-

compulsive disorder and a slightly below-average learning curve. He sees neurologists and

psychiatrists to treat his condition, which is well-managed by medication. Even with medication,

Bogart still shakes his head from left to right in a “no” motion approximately once every minute

or two. Bogart earned a Ph.D. in behavioral neuroscience in 2010 from Kent State University, and

then entered a year-long postdoctoral fellowship in radiology.

In December 2013, Bogart applied for a research position with Dr. Ai-Ling Lin, a

researcher at the University of Kentucky. Originally from Taiwan, Lin received her Ph.D. in

Radiological Sciences from the University of Texas Health Science Center at San Antonio. Her

professional specialties include “risks for Alzheimer’s disease[] and dietary effects on cognitive

aging.” After conducting an interview with Bogart at the University of Kentucky, Lin hired him

as a senior laboratory technician, and he began work in June 2014, subject to a ninety-day

probationary period.

Bogart’s primary assignment was to conduct statistical analysis on a data set that Lin had

purchased from an outside company, Metabolon, Inc. Lin spent $20,000 from a federal research

grant to buy the Metabolon data. The data set contained the results of a study to determine how

caloric restriction affects cognitive aging. Metabolon had performed tests on mouse brains and

then performed preliminary analysis on the resulting data.

Reviewing the Metabolon data, Bogart noticed serious flaws: there were “a number of

very significant outliers that could not be attributed to natural phenomena,” with “data from certain

-2- No. 18-5029, Bogart v. Univ. of Ky.

mouse brains . . . missing and unaccounted for.” According to Bogart, the flaws1 in the data meant

that he “was never able to produce results to Dr. Lin’s satisfaction.” Bogart spoke with Lin about

his concerns, but she allegedly refused to address the problem.

Around August 1, 2014, Lin called Bogart into her office and asked if he had Parkinson’s

disease—she had noticed that he shakes his head back and forth. Bogart replied that he did not

have Parkinson’s disease but did have lesions on his brain. Lin allegedly “became angry and

questioned why [Bogart] had not told her about the lesion on [his] brain during [his] interview for

the job.” In an email sent later that day, Bogart elaborated on his condition and explained that he

“ha[d] a slower learning curve than is usual for what you expect. But all of a sudden, I completely

‘get’ it—people are always fooled by my true abilities because of this.” By email, Lin thanked

him for explaining his condition and said that her concern was “not the speed of [Bogart’s] learning

curve, but the skills and professionalism [he] should already have after [his] Ph.D. training and so

many years of experiences, e.g., the statistical analysis ability.”

As Lin’s email suggests, there had been “discord” between Lin and Bogart. Bogart says

that, though Lin’s English was “excellent,” “[t]hroughout [his] employment,” she would

repeatedly ask him whether he could understand her English and would “say[] something to the

effect of ‘maybe I’m not getting through to you.’” Lin would also say that Bogart’s “inability to

complete the analysis was because she had ‘set the bar too high’ for [him], and that maybe [he]

was incapable of doing ‘this kind of work.’” Bogart claims that Lin would often become angry

with him and raise her voice. For her part, Lin contends that “Bogart began to exhibit substandard

1 The record suggests the Metabolon data was flawed. Following his termination, Bogart reported his concerns about the data to the U.S. Department of Health and Human Services’ (DHHS) Office of Research Integrity, Division of Investigative Oversight. DHHS’s resulting report largely confirmed Bogart’s concerns with the data. -3- No. 18-5029, Bogart v. Univ. of Ky.

performance in late June[] 2014.” Bogart’s alleged deficiencies included forgetting to clock in

and out at appropriate times; working more than forty hours per week after being instructed not to

do so; failing to complete assignments; sleeping in the lab; chatting socially during work hours;

and communicating with sales representatives in a capacity beyond his job description.

Furthermore, on multiple occasions, Bogart mislabeled columns of data that he was analyzing and

mistakenly “swapped numbers” between those columns. Lin says that these were “very serious”

errors.2 Lin also claims that Bogart frequently was rude and insubordinate toward her and spoke

to her in a derogatory manner.

Bogart admits most of these allegations but tries to qualify or downplay his errors. He says

that he never actually “swapped numbers” but only, “on a few occasions,” reversed the headings

on two columns of data, which, he says, were insignificant mistakes “commonly made when

dealing with tremendous quantities of data.” Similarly, Bogart admits he once chatted with an IT

professional, but he claims he did so only while the professional was working on his computer.

He says he “was never aware of any occasion” when he fell asleep in Lin’s lab but was “informed

of one occasion on which others say that [he] fell asleep.”

The University’s account of Bogart’s misconduct was detailed in a written summary of an

oral warning that Bogart received during an August 26 meeting with Lin and two University

administrators. At this point, Bogart was still within his initial probationary period of employment.

And after summarizing Bogart’s inadequate performance and setting out required measures for

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