Hostettler v Coll. of Wooster, 895 F.3d 844, WL 343224 (6th Cir. 2018)
Keywords: ADA, ADA – general, civil procedure, education, employment, legal concepts, medical and health care
Heidi Hostettler was fired from her job in the Human Resources Department at the College of Wooster. Wooster is a private college. Hostettler had a diagnosis of postpartum depression and separation anxiety after giving birth. She stated that Wooster violated a number of laws, including the Americans with Disability Act (ADA). The Sixth Circuit Court of Appeals considered multiple claims. The Court reviewed the case and then reversed and remanded it for further proceedings.
Facts of the Case
Wooster hired Hostettler when she was four months pregnant. When she told them about her pregnancy, Wooster said that they would accommodate her. They would allow her 12 weeks of unpaid maternity leave. Before her maternity leave, Hostettler was an excellent employee.
Hostettler took her full 12 weeks of maternity leave. However, she began to have mental health concerns after she had her baby. She was diagnosed as having postpartum depression and separation anxiety. Her doctor, David Seals, testified that Hostettler’s impairments were one of the worst cases he had ever treated. Dr. Seals prescribed an antidepressant. He also stated that Hostettler should not return to work after 12 weeks. He noted that when she did return to work, she would need a reduced schedule for the “foreseeable future.”
Hostettler met with her supervisor, Marcia Beasley, who allowed her additional maternity leave.. After three more weeks (15 weeks of leave), Hostettler returned to work with a part-time schedule of five half-days per week. Dr. Seals stated that this schedule was medically necessary.
Hostettler performed her job for the next two months. A colleague, Natalie Richardson testified that Hostettler performed all her duties. Hostettler responded to emails from home, which was a common office practice. Richardson was not aware of any instance where Hostettler did not complete work that she was assigned. Richardson was also not aware that her department had any issues with the quality of Hostettler’s work.
Beasley agreed that Hostettler worked well with coworkers and was able to find quick solutions to problems. Shortly before she was fired, Hostettler received her first evaluation with no negative feedback. However, Beasley felt Hostettler’s changed schedule put a strain on the department. Beasley stated that she did not perform the essential functions of the job because she left work unfinished or ignored. However, Beasley was unable to give a specific example(s) of this behavior.
Hostettler had several meetings with Beasley before she was fired. In these meetings, it was stressed that the college needed her on a full-time basis. Hostettler said that one of these meetings was the review with positive feedback. This review had no mention of full-time work. At another meeting, Hostettler wanted to try to extend her hours past noon, but Beasley was not interested. Dr. Seals sent another medical certification form affirming that Hostettler was able to work only five half-days. Hostettler followed up with Beasley asking to extend her hours. Beasley never responded. The next day Beasley fired her citing that the medical certification required her to work part-time and her position required a full-time capacity.
After being fired, Hostettler sued College of Wooster for a number of claims, including violations of the ADA. Wooster moved for summary judgment on all claims and Hostettler moved for a partial summary judgment on her ADA claim.
The district court granted summary judgement for Wooster on all claims and denied Hostettler’s motion. Hostettler appealed the decision to the Sixth Circuit Court of Appeals. The Court of Appeals disagreed with the district court, and reversed the lower court decision. This brief looks at Hostettler’s ADA specific claims. However, when it remanded the case, the Court also considered her other claims.
Issues of the Case
- What is required for summary judgment?
- What is required to prove an ADA direct discrimination claim?
- What is required to prove that an individual has a disability?
- What is required to prove that an individual is otherwise qualified?
- What is required to prove a failure in the interactive process required when an employee requests an accommodation?
Arguments & Analysis
1. What is required for summary judgment?
Summary judgment means that there is no dispute of the facts in a case. As part of her suit, Hostettler moved for partial summary judgment on her ADA claim. The District Court denied Hostettler’s motion. The Court on appeal indicated there was disagreement between the parties regarding the facts of the case. The District Court, however, considered the evidence and decided against Hostettler. This was a misuse of the summary judgment standard.
2. What is required to prove an ADA direct discrimination claim?
Hostettler appealed an ADA direct discrimination claim. The Court of Appeals laid out what is required to prove direct discrimination under the ADA. In order to claim direct discrimination, a plaintiff must prove that (1) they have a disability and (2) they are qualified for a job despite the disability. The plaintiff can show that they are qualified without accommodation from the employer, with an “essential” job requirement eliminated, or with a reasonable accommodation.
The Court of Appeals applies this test when the plaintiff states that there was a failure to accommodate because there will be evidence to show that no accommodation was made. Beasley said that Hostettler was fired because Wooster could not accommodate her modified, part-time schedule.
3. What is required to prove that an individual has a disability?
College of Wooster maintained Hostettler was not an individual with a disability because her panic attacks were of short duration. The college also stated that Hostettler wanted to work half days because it was summer. However, the Court indicated that the definition of disability is broadly interpreted.
The court found that Hostettler was an individual with a disability based on the evidence from Dr. Seals and Richardson. Dr. Seals said that Claimant, Hostettler, had a severe case of separation anxiety, cried in his office, did not like herself, and required antidepressants. Richardson testified that Hostettler’s conditions caused panic attacks and limited concentration. Despite the short time period, the panic attacks would limit Hostettler’s major life activity when they occurred.
4. What is required to prove that an individual is otherwise qualified?
The Court said that this case rested on whether Hostettler was an otherwise qualified individual. An otherwise qualified individual is someone who can perform the essential functions of a job with or without an accommodation. If you could remove this core function and it would alter the job, then it is an essential function. This depends on the facts of the case.
Hostettler testified that she met all the core tasks and completed all her work on time. Richardson and Beasley also said that Hostettler’s work was sufficient to perform her tasks. However, Beasley noted that the part-time schedule was putting a strain on the department and some responsibilities were not completed. This competing evidence is what made the summary judgment, discussed above, improper.
5. What is required to prove a failure in the interactive process required when an employee requests an accommodation?
When an employee asks for an accommodation, there should be a process to figure out how the disability limits the employee and what accommodations would help the employee overcome these limitations. This process must be done in “good faith” (both sides working together to find a solution). This process is specific to the individual and their job.
Wooster and Hostettler met four times and talked about her employment. Hostettler and Wooster disagree on what was discussed at these meetings. Wooster stated that Hostettler would settle for nothing less than part-time work. Hostettler argued that she wanted to extend her hours as a way of helping her move back to full-time work. This competing evidence is why the summary judgment standard was incorrect.
The Sixth Circuit Court of Appeals disagreed with the District Court. The Court found that Hostettler’s claims had issues of fact that prohibited them from allowing summary judgment. The case was reversed and returned to the District Court could evaluate the facts.
Policy & Practice
This decision provides guidance on how to determine summary judgement. The case also defines direct discrimination against a person with a disability and who counts as a person with a disability and as an otherwise qualified individual. This case clarifies the meaning of “interactive process.” Many of these terms are key factors in finding that an ADA violation has occurred. Some rules of law that stand out are:
- An otherwise qualified individual is someone who can perform the essential functions of a job with or without an accommodation.
- When an employee requests an accommodation, there should be an interactive, or shared, process to identify how the disability effects the and the potential reasonable accommodations that would overcome the limitations.
- Full Case Brief – Hostettler v Coll. of Wooster, 895 F.3d 844, WL 343224 (6th Cir. 2018) [PDF]
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