Cite. Research. Draft.
Without the Westlaw bill.

Summary judgment must be granted where the pleadings, depositions, answers to interrogatories, and admissions on file, together with any affidavits, show that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law.[Celotex Corp. v. Catrett, 477 U.S. 317 (1986).]✓ Celotex Corp. v. Catrett, 477 U.S. 317Grounded to“if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.”Verified Anderson further holds that the mere existence of a scintilla of evidence in support of the nonmoving party’s position is insufficient, and that the trial judge’s function is not to weigh the evidence but to determine whether there is a genuine issue for trial.[Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986).]✓ Anderson v. Liberty Lobby, Inc., 477 U.S. 242Grounded to“The mere existence of a scintilla of evidence in support of the plaintiff’s position will be insufficient; there must be evidence on which the jury could reasonably find for the plaintiff.”Verified Exhibit A’s written job description lists “safe operation of powered industrial trucks (forklifts, reach trucks, and electric pallet jacks)” among the core duties of the Warehouse Associate position, a contemporaneous, pre-dispute document that is precisely the kind of evidence the ADA credits as strong indicia of an essential function.[Ex. A.]✓ Ex. AGrounded to“Safe operation of powered industrial trucks (forklifts, reach trucks, and electric pallet jacks) to load, unload, stack, and retrieve palletized goods.”Verified Exhibit B’s first restriction bars Reyes from “operation of powered industrial equipment, including forklifts and powered pallet jacks,” directly and completely prohibiting the forklift duty identified in Exhibit A.[Ex. B.]✓ Ex. BGrounded to“No operation of powered industrial equipment, including forklifts and powered pallet jacks.”Verified Exhibit C’s final written warning is the critical distinguishing fact: even if other associates committed similar unsecured-load errors, Reyes’s incident occurred after he had already received a final warning, making termination the documented, foreseeable next disciplinary step for him specifically.[Ex. C.]✓ Ex. CGrounded to“Marcos acknowledged the warning and was advised that any further load-securement violation would result in termination.”Verified Incident Report IR-2025-0227 records that at approximately 14:42 on February 27, 2025, in Outbound Staging Lane 3 of the Vernon distribution center, a stack of palletized goods staged for outbound transport shifted and partially collapsed after being prepared and released by Reyes.[Ex. D.]✓ Ex. DGrounded to“At approximately 14:42, a stack of palletized goods staged for outbound transport in Lane 3 shifted and partially collapsed. The load had been prepared and released by Associate Marcos Reyes.”Verified Calderon’s termination memorandum states that Reyes’s discharge was “for violation of the Company’s safety policies, specifically the Load Securement Standard, following a prior final written warning for the same category of violation,” and that the decision “is based on your documented safety record and is unrelated to any other factor.”[Ex. E.]✓ Ex. EGrounded to“This decision is based on your documented safety record and is unrelated to any other factor.”Verified Reyes never requested any accommodation for his restrictions.⊘ Blocked — no source. Not drafted.