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Carolyn Humphrey v. Memorial Hospitals Association

Court of Appeals for the Ninth Circuit
239 F.3d 1128, 2001 Daily Journal DAR 1631, 11 Am. Disabilities Cas. (BNA) 765 (2001)
ELI5:

Rule of Law:

Under the Americans with Disabilities Act (ADA), an employer's duty to provide reasonable accommodation is a continuing one that is not exhausted by a single effort. When an initial accommodation proves ineffective, the employer must engage in a good-faith interactive process to explore alternative accommodations before taking adverse employment action.


Facts:

  • Carolyn Humphrey worked for Memorial Hospitals Association (MHA) as a medical transcriptionist from 1986 and her job performance was consistently excellent.
  • Beginning in 1989, Humphrey developed obsessive rituals that caused significant problems with tardiness and absenteeism.
  • In 1994, MHA issued disciplinary warnings to Humphrey for her attendance issues.
  • In May 1995, a psychiatrist diagnosed Humphrey with Obsessive Compulsive Disorder (OCD) and informed MHA in writing that her OCD was directly contributing to her problems with lateness.
  • In June 1995, MHA and Humphrey agreed to a flexible start-time arrangement as an accommodation for her disability.
  • Humphrey's attendance problems continued despite the flexible schedule, and in September 1995, she sent an e-mail requesting to work from home as a new accommodation.
  • MHA summarily denied the work-from-home request, citing her prior disciplinary record for absenteeism, and did not suggest or explore any alternative accommodations.
  • On October 10, 1995, MHA terminated Humphrey, stating the reason was her history of tardiness and absenteeism.

Procedural Posture:

  • Carolyn Humphrey brought suit against Memorial Hospitals Association (MHA) in the U.S. district court.
  • Humphrey alleged violations of the Americans with Disabilities Act (ADA) and California's Fair Employment and Housing Act (FEHA).
  • MHA filed a motion for summary judgment.
  • The district court granted summary judgment in favor of MHA.
  • Humphrey, as the appellant, appealed the district court's judgment to the U.S. Court of Appeals for the Ninth Circuit.

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Issue:

Does an employer violate the Americans with Disabilities Act (ADA) by terminating an employee for conduct caused by their disability after an initial accommodation proves ineffective, without engaging in an interactive process to explore other potential reasonable accommodations?


Opinions:

Majority - Reinhardt

Yes, an employer violates the ADA by terminating an employee for disability-related conduct after an initial accommodation fails without exploring other potential accommodations. The ADA imposes a mandatory and continuing obligation on employers to engage in an interactive process with an employee to identify an effective reasonable accommodation. This duty is not exhausted by one effort. When MHA became aware that the flexible work schedule was failing, it had an affirmative duty to explore other potential accommodations with Humphrey, such as the work-at-home arrangement she requested or a leave of absence suggested by her doctor. MHA's summary denial of her request and its failure to discuss alternatives constituted a failure to engage in the interactive process in good faith. Because a reasonable accommodation, such as a leave of absence, was possible and would not have created an undue hardship, MHA's failure to provide one before terminating her for conduct caused by her disability violated the ADA.



Analysis:

This case solidifies that the ADA's 'interactive process' is an ongoing, dynamic obligation, not a static, one-time event. It establishes that an employer's duty to accommodate is not discharged simply because a first attempt fails. The decision shifts the burden to the employer to proactively explore alternatives when an accommodation is known to be ineffective, preventing employers from remaining passive and then terminating an employee. Furthermore, the ruling prevents employers from using an employee's past disciplinary record—when that record is a result of the disability itself—as a justification for denying a reasonable accommodation, which would create a circular and unjust outcome.

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