Collier v. Harland Clarke Corp.: Reinforcing a High Bar: Eleventh Circuit Rules in Favor of Employer on Disability, Age Discrimination, and Privacy Claims

In Collier v. Harland Clarke Corp., the U.S. Court of Appeals for the Eleventh Circuit addressed a claim brought by a sixty-one-year-old terminated employee against his employer alleging violations of the Americans with Disabilities Act (the “ADA”), the Age Discrimination in Employment Act (the “ADEA”), and Alabama privacy law. Although the Eleventh Circuit expressed sympathy for Collier in his termination, the court held the district court did not err in granting summary judgment in favor of the employer because there were no genuine issues of material fact for any of Collier’s claims. Collier is significant in the employment discrimination context because it reaffirms the notion that in order to survive summary judgment, a plaintiff must provide enough evidence to establish a prima facie case of discrimination and an employer’s discriminatory intent beyond mere speculation.