Fluker v. United States Postal Service

Andre Fluker, a former letter carrier for the United States Postal Service, filed a lawsuit alleging that his termination constituted unlawful retaliation. Fluker claimed he was fired because he had previously filed complaints of disability discrimination and requested reasonable accommodations. The USPS argued that the dismissal was based on legitimate, non-discriminatory reasons, citing Fluker's documented history of poor attendance and violations of workplace rules. The district court granted summary judgment in favor of the Postal Service, finding that Fluker failed to establish a causal link between his protected activities and his discharge. On December 17, 2018, the U.S. Court of Appeals for the Third Circuit affirmed this decision.

The district court's grant of summary judgment in favor of the United States Postal Service was affirmed by the Third Circuit Court of Appeals.

Whether the United States Postal Service terminated Andre Fluker in retaliation for his protected activity of filing disability discrimination complaints and requesting accommodations, in violation of federal anti-discrimination statutes.

The decision reinforced the rigorous causation standard required for retaliation claims, clarifying that an employee must prove retaliatory motive was the "but-for" cause of the adverse action, not merely a motivating factor. It serves as a significant precedent emphasizing the necessity for plaintiffs to present strong circumstantial evidence to survive summary judgment in the face of documented performance issues.