Colasanti v. City of Portland

District Court, D. Oregon·Decided August 19, 2025·No. 3:19-cv-00443·Unknown

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF OREGON PORTLAND DIVISION

LOU COLASANTI,

Plaintiff, Case No. 3:19-cv-00443-YY v. OPINION AND ORDER CITY OF PORTLAND and STATE OF OREGON,

Defendants.

Following a jury verdict in favor of defendant City of Portland on plaintiff’s claims of disability discrimination under the Americans with Disabilities Act (“ADA”) and O.R.S. 659A.112, the court held a bench trial on plaintiff’s remaining equitable claim of ADA interference against the City and the State of Oregon. This Opinion and Order comprises the findings of fact and conclusions of law required by Federal Rule of Civil Procedure 52(a). The court has considered the sworn testimony received during the bench trial, the exhibits and transcripts of prior testimony submitted by the parties, and the parties’ arguments, and finds in favor of defendants.1 I. Relevant Law and Scope of Plaintiff’s Interference Claim Section 503(b) provides:

1 Although this Opinion and Order does not recount all of the evidence presented at the bench trial, the court has considered it all in reaching this verdict. It shall be unlawful to coerce, intimidate, threaten, or interfere with any individual in the exercise or enjoyment of, or on account of his or her having exercised or enjoyed, or on account of his or her having aided or encouraged any other individual in the exercise or enjoyment of, any right granted or protected by this chapter.

42 U.S.C. § 12203(b). Plaintiff’s interference claim is limited to the first prong of § 503(b), that the City and State interfered with him “in the exercise or enjoyment of” his rights under the ADA, and to the actions of Portland Police Bureau Sgt. William Goff, plaintiff’s training supervisor, and Lt. Donald Sedlacek, a class coordinator at the State’s Department of Public Safety Standards and Training (“DPSST”) academy.2 See Findings and Recommendations 11-18, 32-34, ECF 65, adopted by Order, ECF 67; Opinion and Order, 13-24, ECF 124. To prevail, plaintiff must identify an ADA-protected right, show that defendants interfered with the exercise or enjoyment of that right, and prove that he suffered a distinct and palpable injury as a result. See Brown v. City of Tucson, 336 F.3d 1181, 1194 (9th Cir. 2003); Annenberg v. Clark Cty. Sch. Dist., 818 F. App’x 674, 678 (9th Cir. 2020). The Ninth Circuit has yet to decide whether a plaintiff must also show a causal link between the protected conduct and the adverse action. See Bayer v. Neiman Marcus Grp., Inc., 843 F. App’x 74, 75–76 (9th Cir. 2021) (recognizing that Brown “did not resolve the precise legal standard that applied,” and finding that the plaintiff “presented sufficient evidence to prevail on his § 503(b) claim regardless of which legal standard applies”). However, courts across the country, including in the

2 On summary judgment, this court found that none of the actions by either Goff or Sedlacek constitutes intimidation—there was no evidence in the record that their actions frightened plaintiff. Walker v. City of Lakewood, 272 F.3d 1114, 1129 (9th Cir. 2001)(“‘Intimidation’ would require a showing that the City’s activities had generated fear in the [plaintiff].”) (citing Webster’s Third New Int'l Dict. 1184 (14th ed 1961)); see Opinion and Order (October 17, 2023) 22, ECF 124. Ninth Circuit, have required an additional causality and/or discriminatory intent element.3 See Bayer v. Neiman Marcus Grp., Inc., No. 13-CV-04487-MEJ, 2018 WL 2427787, at *7 (N.D. Cal. May 30, 2018) (citing Frakes v. Peoria Sch. Dist. No. 150, 872 F.3d 545, 550–51 (7th Cir. 2017), and collecting cases).

Requesting an accommodation is a protected ADA activity. Coons v. Secretary of U.S. Dept. of Treasury, 383 F.3d 879, 887 (9th Cir. 2004). The term “interfere” is not defined in § 503(b). The Ninth Circuit has instructed that the “construction and application of § 503(b) ought to be guided by [the court’s] treatment” of the Fair Housing Act (“FHA”) interference provision, “as well as similar provisions” in the Family and Medical Leave Act (“FMLA”) and National Labor Relations Act (“NLRA”). Brown, 336 F. 3d at 1191. In the FHA context, the Ninth Circuit has defined “interference” as “the act of meddling in or hampering an activity or process.” Walker v. City of Lakewood, 272 F.3d 1114, 1129 (9th Cir. 2001) (quoting Webster’s Third New Int’l Dict. 1178 (14th ed. 1961)). The definition of “interference” is “broadly applied to reach all practices which have the effect of interfering with the exercise of rights under the federal fair

housing laws.” Brown, 336 F.3d at 1191 (citing United States v. City of Hayward, 36 F.3d 832,

3 While this does not constitute an exhaustive list, the cases include: Kelly v. Town of Abingdon, Virginia, 90 F.4th 158, 171 (4th Cir. 2024) (applying the Frakes four-factor test); Fernandes v. Criterion Child Enrichment, Inc., No. 4:21-CV-40124-MRG, 2024 WL 4393330, at *11 (D. Mass. Sept. 30, 2024); Golden Gate Transactional Indep. Serv., Inc. v. California, No. CV1808093SJOAGRX, 2019 WL 4222452, at *21 (C.D. Cal. May 1, 2019); Baack v. Asurion, LLC, No. 2:20-CV-00336-KJD-BNW, 2022 WL 22876260, at *4 (D. Nev. Mar. 7, 2022); Lagervall v. Missoula County Pub. Sch., 2017 WL 3610549, at *5 (D. Mont. Aug. 22, 2017); Youngblood v. Prudential Ins. Co., 706 F. Supp. 2d 831, 840 (M.D. Tenn. 2010); see also Dedyo v. Baker Eng'g New York, Inc., 1998 WL 9376, at *11 (S.D.N.Y. Jan. 13, 1998) (“As other courts have commented, the sine qua non of an ADA claim is that the plaintiff was treated differently ‘because of’ his impairment.”); Michigan Prot. & Advoc. Serv., Inc. v. Babin, 18 F.3d 337, 347 (6th Cir. 1994) (requiring discriminatory animus in the context of an FHA interference claim). 835 (9th Cir. 1994) (analyzing the FHA’s anti-interference provision)). However, “[c]learly, antiinterference provisions such as those contained in the FHA and ADA cannot be so broad as to prohibit ‘any action whatsoever that in any way hinders a member of a protected class.’” Id. In Brown, the Ninth Circuit found that some of the conduct the plaintiff complained

about did not rise to a violation under § 503(b), specifically comments by her supervisor that she was “sloughing off” and “goofing off,” and reports that colleagues complained about her early departures and long lunches. Id. at 1193. However, the plaintiff also claimed she was threatened when her supervisor demanded that she cease her medications and work evening shifts or face demotion or forced retirement. Id. The Ninth Circuit found that these were “actionable threats” and the “allegations of direct harm resulting” from these threats, specifically, “short-term memory problems” and feeling “extremely stressed, harassed, and pressured,” “would constitute a violation of § 503(b) if proven at trial.” Id.

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