Dive Brief:

• A law firm in Nevada with fewer than 15 employees may have to defend an associate’s Americans with Disabilities Act lawsuit due to Title VII’s “integrated enterprise” doctrine, the 9th U.S. Circuit Court of Appeals held (Buchanan v. Watkins & Letofsky, LLP, No. 21-15633 (9th Cir. April 7, 2022)).
• Two partners own the Nevada firm (W&L Nevada). They also own and run a law firm in California (W&L California). The associate worked in the Nevada firm and alleged the company failed to accommodate her medical condition by requiring her to work more than 20 hours a week. A federal district court found that W&L Nevada was not covered by the ADA because it had fewer than 15 employees, the threshold for coverage, and the associate failed to show it should be treated as a single employer with W&L California.
• On appeal, the 9th Circuit reversed. In a case of first impression for the court, the 9th Circuit held that Title VII’s “integrated enterprise” doctrine also applies to ADA claims. The two statutes have the same 15-employee threshold and statutory enforcement schemes, and the court has long analyzed the two statutes along similar lines, the panel said. Based on four factors — including interrelated operations — the evidence raised a question about whether W&L Nevada and W&L California were, in fact, an integrated enterprise and could be treated as a single employer for purposes of coverage under the ADA, the 9th Circuit held. It sent the...

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