CACI No. 2547

Factual Elements

[Name of plaintiff] claims that [name of defendant] wrongfully

discriminated against [him/her/ nonbinary pronoun] based on

[his/her/nonbinary pronoun] association with a person with a disability. To

establish this claim, [name of plaintiff] must prove all of the following:

1. That [name of defendant] was [an employer/[other covered entity]];

2. That [name of plaintiff] [was an employee of [name of defendant]/

applied to [name of defendant] for a job/[describe other covered

relationship to defendant]];

3. That [name of plaintiff] was [specify basis of association or

relationship, e.g., the brother of [name of associate]], who had [a]

[e.g., physical condition];

4. [That [name of associate]’s [e.g., physical condition] was costly to

[name of defendant] because [specify reason, e.g., [name of

associate] was covered under [plaintiff]’s employer-provided health

care plan];]

4. [or]

4. [That [name of defendant] feared [name of plaintiff]’s association

with [name of associate] because [specify, e.g., [name of associate]

has a disability with a genetic component and [name of plaintiff] may

develop the disability as well];]

4. [or]

4. [That [name of plaintiff] was somewhat inattentive at work

because [name of associate]’s [e.g., physical condition] requires

[name of plaintiff]’s attention, but not so inattentive that to

perform to [name of defendant]’s satisfaction [name of plaintiff]

would need an accommodation;]

4. [or]

4. [[Specify other basis for associational discrimination];]

5. That [name of plaintiff] was able to perform the essential job

duties;

6. [That [name of defendant] [discharged/refused to hire/[other

adverse employment action]] [name of plaintiff];]

6. [or]

6. [That [name of defendant] subjected [name of plaintiff] to an

adverse employment action;]

6. [or]

6. [That [name of plaintiff] was constructively discharged;]

7. That [name of plaintiff]’s association with [name of associate] was a

substantial motivating reason for [name of defendant]’s [decision

to [discharge/refuse to hire/[other adverse employment action]]

[name of plaintiff]/conduct];

8. That [name of plaintiff] was harmed; and

9. That [name of defendant]’s conduct was a substantial factor in

causing [name of plaintiff]’s harm.

New December 2014; Revised May 2017, May 2020, November 2023, May 2024*,

December 2025*