Kristin Simmons v. UM Capital Region Health, Inc.

Court of Appeals for the Fourth Circuit·Decided July 20, 2026·No. 25-1430·Unpublished

Opinion

USCA4 Appeal: 25-1430 Doc: 43 Filed: 07/20/2026 Pg: 1 of 18

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 25-1430

KRISTIN SIMMONS,

Plaintiff – Appellant,

v.

UM CAPITAL REGION HEALTH, INC.; DIMENSIONS HEALTH CORPORATION, d/b/a UM Capital Region Health, Inc.,

Defendants – Appellees.

Appeal from the United States District Court for the District of Maryland, at Greenbelt. Matthew James Maddox, District Judge. (8:21-cv-02074-MJM)

Argued: December 11, 2025 Decided: July 20, 2026

Before DIAZ, Chief Judge, and RUSHING and HEYTENS, Circuit Judges.

Affirmed by unpublished opinion. Judge Rushing wrote the opinion, in which Chief Judge Diaz and Judge Heytens joined.

ARGUED: Reuben W. Wolfson, SMITHEY LAW GROUP LLC, Annapolis, Maryland, for Appellant. Alison Nadine Davis, LITTLER MENDELSON, P.C., Washington, D.C., for Appellees. ON BRIEF: Joyce E. Smithey, Liesel J. Schopler, SMITHEY LAW GROUP LLC, Annapolis, Maryland, for Appellant. Morgan L. Kinney, LITTLER MENDELSON, P.C., Washington, D.C., for Appellees. USCA4 Appeal: 25-1430 Doc: 43 Filed: 07/20/2026 Pg: 2 of 18

Unpublished opinions are not binding precedent in this circuit.

2 USCA4 Appeal: 25-1430 Doc: 43 Filed: 07/20/2026 Pg: 3 of 18

RUSHING, Circuit Judge:

Kristin Simmons sued her former employer, UM Capital Region Health, Inc. (UM

Capital), and its related entity Dimensions Health Corporation, alleging that UM Capital

terminated her employment for discriminatory reasons in violation of the Americans with

Disabilities Act (ADA) and for retaliatory reasons in violation of the False Claims Act

(FCA) and the Maryland False Health Claims Act (MFHCA). 1 The district court granted

summary judgment in favor of Defendants. We affirm.

I.

We review the district court’s “grant of summary judgment de novo, applying the

same legal standards as the district court.” Cowgill v. First Data Tech., Inc., 41 F.4th 370,

378 (4th Cir. 2022) (internal quotation marks omitted). Summary judgment is appropriate

“if the movant shows that there is no genuine dispute as to any material fact and the movant

is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). A genuine dispute of

material fact exists when, viewing all facts and reasonable inferences in the light most

favorable to the non-moving party, a court finds that a reasonable jury could return a verdict

in that party’s favor. Dulaney v. Packaging Corp. of Am., 673 F.3d 323, 330 (4th Cir.

2012).

A.

Simmons has fascia scapular humeral muscular dystrophy, a neuromuscular

disorder that makes it difficult to control her facial muscles, and alleges that UM Capital

1 Simmons also asserted other claims that are not on appeal. 3 USCA4 Appeal: 25-1430 Doc: 43 Filed: 07/20/2026 Pg: 4 of 18

terminated her employment for discriminatory reasons in violation of the ADA. UM

Capital maintains that it terminated Simmons’s employment “because of her rude and

disrespectful behavior that on occasion amounted to insubordination and negatively

impacted the overall collaborat[ive] environment and team building efforts” that her

supervisor, Yeo-Jin Lee, and Lee’s supervisor, Ingrid Connerney, “were making efforts to

improve.” J.A. 69.

The ADA prohibits employers from “discriminat[ing] against a qualified individual

on the basis of disability in regard to . . . the . . . discharge of employees.” 42 U.S.C.

§ 12112(a). “To establish a claim for disability discrimination under the ADA, a plaintiff

must prove (1) that she has a disability, (2) that she is a qualified individual for the

employment in question, and (3) that her employer discharged her (or took other adverse

employment action) because of her disability.” Jacobs v. N.C. Admin. Off. of the Cts., 780

F.3d 562, 572 (4th Cir. 2015) (internal quotation marks and brackets omitted). The plaintiff

must establish that her disability was a but-for cause of the adverse employment action.

Gentry v. E. W. Partners Club Mgmt. Co., 816 F.3d 228, 235–236 (4th Cir. 2016).

A plaintiff may prove disability discrimination through the McDonnell Douglas

burden-shifting framework. McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802–804

(1973); Jacobs, 780 F.3d at 572. Under that framework, the plaintiff bears the initial

burden of establishing a prima facie case of discrimination. 2 Wannamaker-Amos v. Purem

2 “To establish a prima faci[e] case of disability discrimination, a plaintiff must show (i) she was disabled, (ii) she was discharged, (iii) she was fulfilling her employer’s legitimate expectations when she was discharged, and (iv) the circumstances of her

4 USCA4 Appeal: 25-1430 Doc: 43 Filed: 07/20/2026 Pg: 5 of 18

Novi, Inc., 126 F.4th 244, 255 (4th Cir. 2025). “The burden of production then shifts to

the employer to articulate a legitimate, non-discriminatory justification for its allegedly

discriminatory action.” Id. “If the employer carries this burden, the plaintiff then must

prove by a preponderance of the evidence that the neutral reasons offered by the employer

‘were not its true reasons, but were pretext for discrimination.’” Id. (quoting Tex. Dep’t of

Cmty. Affs. v. Burdine, 450 U.S. 248, 253 (1981)).

UM Capital proffered a legitimate, non-discriminatory reason for Simmons’s

termination, and we will assume, without deciding, that Simmons has made a prima facie

case of discrimination. See, e.g., Hux v. City of Newport News, 451 F.3d 311, 314 (4th Cir.

2006); Rowe v. Marley Co., 233 F.3d 825, 829 (4th Cir. 2000).

Simmons’s ADA discrimination claim fails, however, at the third step of the

McDonnell Douglas burden-shifting framework. At this step, a plaintiff must “show[] both

that the [proffered] reason was false, and that discrimination was the real reason” for the

adverse employment action. St. Mary’s Honor Ctr. v. Hicks, 509 U.S. 502, 515 (1993).

“[U]nder the appropriate circumstances, ‘a plaintiff’s prima facie case, combined with

sufficient evidence to find that the employer’s asserted justification is false, may permit

the trier of fact to conclude that the employer unlawfully discriminated.’” EEOC v. Sears

Roebuck & Co., 243 F.3d 846, 852 (4th Cir. 2001) (quoting Reeves v. Sanderson Plumbing

Prods., Inc., 530 U.S. 133, 148 (2000)).

discharge raise a reasonable inference of unlawful discrimination.” Cowgill, 41 F.4th at 379. 5 USCA4 Appeal: 25-1430 Doc: 43 Filed: 07/20/2026 Pg: 6 of 18

However, “if ‘no rational factfinder could conclude that the employer’s job action

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