Buchanan

NOT FOR PUBLICATION FILED

UNITED STATES COURT OF APPEALS NOV 20 2025

MOLLY C. DWYER, CLERK

U.S. COURT OF APPEALS

FOR THE NINTH CIRCUIT

AMY BUCHANAN, No. 24-6236 D.C. No. Plaintiff - Appellant, 2:19-cv-00226-GMN-BNW v.

MEMORANDUM*

WATKINS & LETOFSKY, LLP,

Defendant - Appellee.

Appeal from the United States District Court for the District of Nevada Gloria M. Navarro, District Judge, Presiding

Argued and Submitted October 8, 2025 Las Vegas, Nevada

Before: BENNETT, SANCHEZ, and H.A. THOMAS, Circuit Judges. Dissent by Judge BENNETT.

Amy Buchanan appeals the district court’s grant of summary judgment to

Watkins & Letofsky, LLP on her discrimination and retaliation claims under the

Americans with Disabilities Act (“ADA”), 42 U.S.C. § 12101 et seq. The district

court determined that Watkins & Letofsky was not a covered employer under the

ADA because it did not employ 15 or more employees for 20 or more calendar

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. weeks in 2016 or 2017. We have jurisdiction under 28…