Employment, Labor & Benefits Advisory: District Court Decision Rejects Associational Discrimination Claims under Chapter 151B
1/31/2012
The United States District Court for the District of Massachusetts recently found that an employee cannot bring a claim for discrimination under Chapter 151B based on his association with a handicapped person. In dismissing the plaintiff’s Chapter 151B claim in Ayanna v. Dechert, the court expressly rejected the Massachusetts Commission Against Discrimination’s (MCAD) interpretation that the statute provides a cause of action for associational discrimination. But employers may remain open to associational claims brought under other statutes, including the Americans with Disabilities Act and Title VII.
