Partner Cristina Guerrero successfully secured summary judgment on behalf of a leading manufacturer and supplier of premium building products in the United States District Court for the Northern District of Mississippi, Oxford Division.
The plaintiff, a diabetic with toe amputations, worked as a production operator. During her employment, she took numerous medical leaves and in each instance was able to return to work without issue. However, in April of 2022, following an eight-month absence, her condition worsened, and she was unable to return to work and perform weight-bearing activities such as standing or walking, which are essential functions of her job. At that point, she transitioned from short-term disability to long-term disability, upon which her employment was terminated.
The plaintiff alleged that the employer failed to accommodate her condition by not offering her a sit-down position and that her termination was discriminatorily based on her disability in violation of the Americans with Disabilities Act.
After assessing the evidence, the court determined that the plaintiff’s failure to accommodate and discriminatory discharge claims failed as a matter of law. The plaintiff's accommodation claim was unsuccessful as she could not demonstrate that she is a qualified individual with a disability, given her inability, at the time of termination, to perform a critical function required for the production operator position. The plaintiff also could not demonstrate that the employer failed to make reasonable accommodations. Further, the plaintiff could not show that the employer’s stated reason for the termination of her employment—her transition to long-term disability—was pretextual to support the discriminatory discharge claim. Accordingly, the plaintiff’s claims were dismissed in their entirety.
This ruling illustrates the importance of identifying essential job functions of a position when assessing reasonable accommodations in the context of the Americans with Disabilities Act.
Associate Haylee Friedman was instrumental in the successful defense of this matter.