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.

The plaintiff claimed that his employer terminated him because he took leave and provided continued care to his wife who suffered from chronic mental illness. Among other claims, including violation of the Family and Medical Leave Act, Mr. Ayanna argued that his employer violated Chapter 151B by discriminating against him based on his association with his wife. The argument for associational standing under Chapter 151B was rooted in several MCAD decisions allowing associational standing for similar plaintiffs.

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