Villanueva v. Wal-Mart Inc

CourtDistrict Court, E.D. Washington
DecidedMay 18, 2020
Docket1:18-cv-03125
StatusUnknown

This text of Villanueva v. Wal-Mart Inc (Villanueva v. Wal-Mart Inc) is published on Counsel Stack Legal Research, covering District Court, E.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Villanueva v. Wal-Mart Inc, (E.D. Wash. 2020).

Opinion

1 FILED IN THE U.S. DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 2 May 18, 2020

3 UNITED STATES DISTRICT COURT SEAN F. MCAVOY, CLERK EASTERN DISTRICT OF WASHINGTON 4 MARTIN VILLANUEVA, GABELO No. 1:18-cv-03125-SMJ 5 TLATELPA, and JOHN DOE, Trustee, ORDER GRANTING IN PART 6 AND DENYING IN PART Plaintiffs, DEFENDANTS’ MOTIONS FOR 7 SUMMARY JUDGMENT, AND v. DENYING PLAINTIFFS’ 8 MOTIONS FOR SUMMARY WAL-MART INC., a foreign profit JUDGMENT 9 corporation, JAKE CARLSTROM, and AARON RODRIGUEZ, 10 Defendants. 11

12 Before the Court, without oral argument,1 are Defendants Wal-Mart Inc. 13 (“Walmart”), Jake Carlstrom, and Andrew Rodriguez’s Motion for Summary 14 Judgment on Villanueva’s Claims, ECF No. 120, Defendants’ Motion for Summary 15 Judgment on Tlatelpa’s Claims, ECF No. 122, Plaintiff Martin Villanueva’s Motion 16 for Summary Judgment, ECF No. 126, and Plaintiff Gabelo Tlatelpa’s Motion for 17 Summary Judgment, ECF No. 127. Defendants seek summary judgment on each of 18 1 Though Plaintiffs requested hearing with oral argument on Defendants’ motions, 19 the Court, having reviewed the record, the parties’ briefs, and the relevant legal authorities, is fully informed and finds the motions appropriate for decision without 20 oral argument. See LCivR 7(i)(3)(B)(iii). 1 Plaintiffs’ nine claims related to their respective termination from employment with 2 Walmart. ECF Nos. 120, 122. Plaintiffs seek summary judgment on their claims for

3 discrimination on the basis of disability under the Washington Law Against 4 Discrimination (WLAD) and the Washington Industrial Insurance Act (IIA). ECF 5 Nos. 126, 127. Plaintiff Tlatelpa also seeks summary judgment on his claim for

6 failure to accommodate. ECF No. 127. 7 Having reviewed the motions and the file in this matter, the Court is fully 8 informed. For the reasons discussed below, the Court finds genuine disputes of 9 material fact exist with regard to Plaintiffs’ claims for disability discrimination and

10 wrongful termination in violation of the IIA, and Plaintiff Tlatelpa’s failure to 11 accommodate claim, and therefore summary judgment is inappropriate on those 12 claims. However, the Court finds Defendants are entitled to judgment as a matter

13 of law on Plaintiffs’ hostile work environment claims. 14 BACKGROUND 15 In 2017, Defendants Villanueva and Tlatelpa both worked in Walmart’s 16 Grandview, Washington distribution center, sustained injuries on the job, filed

17 workers’ compensation claims, and were discharged after reaching the fourth and 18 final step of Walmart’s “accountability system.” ECF No. 78 at 3; ECF No. 120 at 19 5–6; ECF No. 122 at 5–7; ECF No. 126 at 2–4; ECF No. 127 at 2–5.

20 // 1 A. Walmart’s Accountability System 2 Defendants assert Walmart employs a “progressive accountability system

3 whereby employees . . . are disciplined to improve their job performance 4 or behavior to meet Walmart’s expectations.” ECF No. 120 at 2–3; ECF No. 122 5 at 2–3. Plaintiffs’ and Defendants’ representation of the exact procedures under this

6 system differ. Defendants assert an incident involving an employee that results in a 7 formal reprimand would be recorded in the employee’s personnel file as an 8 “occurrence until the issue reaches a step level.” ECF No. 120 at 3; ECF No. 122 9 at 3. Plaintiffs assert that this system also permitted recording certain incidents as

10 “events,” which were less severe than an occurrence and that two events would 11 result in a recorded occurrence. ECF No. 126 at 6; ECF No. 127 at 5. 12 Discipline under the accountability system included four steps; reaching the

13 fourth step would result in an employee’s termination. ECF No. 120 at 3; ECF 14 No. 122 at 3. An employee’s status within the accountability system was recorded 15 under two categories—Section A related to safety, procedure, quality, productivity, 16 or other topics, and Section B related to attendance and punctuality. ECF No. 120

17 at 3; ECF No. 122 at 3. Employees could be at Step One or Step Two in either 18 category and incur an additional step without termination, but once the employee 19 reached Step Three in either category, any further step progression in either

20 category would result in progression to Step Four and termination. ECF No. 120 1 at 3–4; ECF No. 122 at 3–4. 2 B. Villanueva’s Employment, Injury, and Termination

3 Plaintiff Villanueva began working for Walmart on November 19, 2007 and 4 was terminated on September 12, 2017. ECF No. 120 at 5. On May 30, 2017, 5 Villanueva was putting away a pallet of water when the cases of water fell. ECF

6 No. 120 at 5; ECF No. 126 at 3. He and a co-worker were putting the cases back on 7 the pallet when the cases of water fell again and struck Villanueva. ECF No. 120 8 at 3; ECF No. 126 at 3. Villanueva sustained injuries to his shoulder and knee. ECF 9 No. 126 at 3. He filed a workers’ compensation claim related to the incident. ECF

10 No. 120 at 6. Defendant asserts Villanueva’s injury was a result of his violation of 11 safety procedures because he placed himself in an unsafe “pinch point” between the 12 rack and the pallet and was therefore unable to avoid being struck by the falling

13 cases. ECF No. 120 at 5–6. Plaintiff Villanueva asserts that he did not place himself 14 in a pinch point and that he had previously used the same method to pick up fallen 15 merchandise without reprimand. ECF No. 126 at 4. 16 Walmart investigated this incident and found Villanueva’s conduct reckless,

17 meriting an immediate escalation to Step Three. ECF No. 120 at 6. Villanueva 18 argues the decision to find his conduct reckless, rather than careless meriting only 19 an escalation to Step One, was part of Defendants’ practice of targeting workers

20 who had been injured in the course of employment and who filed workers’ 1 compensation claims. See ECF No. 126 at 2–3. Villanueva also argues Walmart 2 failed to communicate the finding of recklessness within the time required by

3 Walmart’s policies and that after the incident, Walmart “was looking for any excuse 4 to fire him.” Id. On September 7, 2017, Walmart asserts Villanueva placed a pallet 5 in the wrong location, which resulted in a progression to Step Four and Villanueva’s

6 termination. ECF No. 120 at 6–7. Villanueva asserts he challenged the claim that he 7 had misplaced the pallet, but his challenge was not addressed. ECF No. 126 at 4–5. 8 C. Plaintiff Tlatelpa’s Employment, Injury, and Termination 9 Plaintiff Tlatelpa began working for Walmart on or about November 28, 2016

10 and was terminated on September 14, 2017. ECF No. 122 at 5. On May 25, 2017, 11 Tlatelpa was injured while operating power equipment and filed a workers’ 12 compensation claim. ECF No. 122 at 5–6; ECF No. 127 at 2. Tlatelpa had already

13 received two step-increases, once for taking too long for lunch on March 16, 2017, 14 and once for a fifth incident of failing to make productivity goals in April 2017. 15 ECF No. 122 at 5. Walmart investigated the May 25, 2017 incident resulting in 16 Tlatelpa’s injury, determined he had engaged in reckless behavior, and progressed

17 Tlatelpa’s status from Step Two to Step Three. Id. at 5–6. 18 Defendants assert Tlatelpa failed to timely call Walmart to report his absence 19 on August 31, 2017, resulting in a progression to Step Four and Plaintiff Tlatelpa’s

20 termination. Id. at 6. Tlatelpa asserts that after his injury, he was repeatedly assessed 1 “occurrences” related to missing work for doctors’ appointments and otherwise 2 stemming from the recommended treatment of his injuries, despite Walmart being

3 made aware of these appointments and recommendations in advance. ECF No. 127 4 at 4–5.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Adickes v. S. H. Kress & Co.
398 U.S. 144 (Supreme Court, 1970)
McDonnell Douglas Corp. v. Green
411 U.S. 792 (Supreme Court, 1973)
Price Waterhouse v. Hopkins
490 U.S. 228 (Supreme Court, 1989)
Harris v. Forklift Systems, Inc.
510 U.S. 17 (Supreme Court, 1993)
United States v. Michael Patterson
230 F.3d 1168 (Ninth Circuit, 2000)
MacDonald v. Korum Ford
912 P.2d 1052 (Court of Appeals of Washington, 1996)
Glasgow v. Georgia-Pacific Corp.
693 P.2d 708 (Washington Supreme Court, 1985)
Swinford v. RUSS DUNMIRE OLDSMOBILE, INCORP.
918 P.2d 186 (Court of Appeals of Washington, 1996)
Carle v. McChord Credit Union
827 P.2d 1070 (Court of Appeals of Washington, 1992)
Oliver v. Pacific Northwest Bell Telephone Co.
724 P.2d 1003 (Washington Supreme Court, 1986)
Wilmot v. Kaiser Aluminum & Chemical Corp.
821 P.2d 18 (Washington Supreme Court, 1991)
Goodman v. Boeing Co.
899 P.2d 1265 (Washington Supreme Court, 1995)
Kuyper v. Department of Wildlife
904 P.2d 793 (Court of Appeals of Washington, 1995)
Thompson v. St. Regis Paper Company
685 P.2d 1081 (Washington Supreme Court, 1984)
Ware v. Hylton
3 U.S. 199 (Supreme Court, 1796)
Docusign, Inc. v. Sertifi, Inc.
468 F. Supp. 2d 1305 (W.D. Washington, 2006)
Callahan v. Walla Walla Housing Authority
110 P.3d 782 (Court of Appeals of Washington, 2005)
Adams v. Able Bldg. Supply, Inc.
57 P.3d 280 (Court of Appeals of Washington, 2002)
Clark County School District v. Breeden
532 U.S. 268 (Supreme Court, 2001)
Anica v. Wal-Mart Stores, Inc.
84 P.3d 1231 (Court of Appeals of Washington, 2004)

Cite This Page — Counsel Stack

Bluebook (online)
Villanueva v. Wal-Mart Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/villanueva-v-wal-mart-inc-waed-2020.