Li Lin v. Matthew J. Ellis, and the Washington University in Saint Louis

Summary

The Court held that merely requesting a disability accommodation does not constitute protected activity under the plain language of the Missouri Human Rights Act's retaliation provision. Because Dr. Lin's claim was based solely on her accommodation requests, she failed to submit a cognizable retaliation claim, and the circuit court erred in denying judgment notwithstanding the verdict. The judgment was reversed and the case remanded.