4th Circ. Backs USPS In Bias Suit That Clarified Appeal Rules

Law360 (September 14, 2022, 5:06 PM EDT) — The Fourth Circuit on Wednesday upheld the U.S. Postal Service’s win in a lawsuit from a worker who said she was fired because of a shoulder injury and her age, wrapping up a case that saw the circuit clarify exactly when a lower court dismissal could be appealed.

A three-judge panel affirmed a Maryland district court’s April 2020 dismissal of JoAnn Britt’s Americans with Disabilities Act, Age Discrimination in Employment Act and Rehabilitation Act of 1973 suit, saying she hadn’t pointed to any facts that show her termination was rooted in bias.

The opinion comes a month after the full Fourth Circuit decided it could consider Britt’s appeal, establishing a new rule clarifying that a district court’s dismissal of a complaint that does not allow for amendments constitutes an appealable final order.


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