Heidi Hostettler v. College of Wooster

Court of Appeals for the Sixth Circuit
895 F.3d 844 (2018)

ELI5:

Rule of Law:

Under the Americans with Disabilities Act (ADA), an employer's assertion that full-time presence is an essential function of a job is not, by itself, sufficient to defeat a failure-to-accommodate claim. The employer must demonstrate with evidence why the employee is needed on a full-time basis to perform the core duties of the position, and summary judgment is improper if a genuine dispute of material fact exists as to whether the employee could perform those essential functions with a modified schedule.

Facts:

Heidi Hostettler was hired as a full-time HR Generalist by the College of Wooster while she was four months pregnant.
After taking 12 weeks of maternity leave, Hostettler developed severe postpartum depression and separation anxiety.
Hostettler's doctor determined it was medically necessary for her to return to work on a reduced, part-time schedule for a limited period, estimating she could return to full-time work in 'a month or two.'
Wooster initially accommodated this request, allowing Hostettler to work five half-days a week from late May through June.
During her time on the modified schedule, Hostettler asserted that she completed all her essential job duties, a claim supported by a colleague and her own positive performance review.
Hostettler's direct supervisor, Marcia Beasley, felt strained by the arrangement but, when deposed, was unable to name any specific essential tasks that Hostettler had failed to complete.
In mid-July, after Hostettler's doctor submitted a certification to continue the part-time schedule with an estimated full-time return in September, Beasley fired Hostettler.
The termination letter stated the reason for termination was Hostettler's inability to return to her 'assigned position of HR Generalist in a full time capacity.'

Procedural Posture:

Heidi Hostettler sued the College of Wooster in a federal district court, alleging violations of the ADA, FMLA, and Title VII.
Wooster moved for summary judgment on all claims, and Hostettler moved for partial summary judgment on her ADA claim.
The district court denied Hostettler's motion and granted summary judgment in favor of Wooster on all claims.
Hostettler, as the appellant, appealed the district court's grant of summary judgment to the U.S. Court of Appeals for the Sixth Circuit.
The College of Wooster was the appellee in the appeal.

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Issue:

Under the Americans with Disabilities Act, can an employer establish that full-time presence is an essential function of a job, sufficient to defeat a failure-to-accommodate claim at the summary judgment stage, merely by stating it is required, without showing why the employee's core duties cannot be performed on a modified schedule?

Opinions:

Majority - Martha Craig Daughtrey

No. An employer cannot defeat an ADA failure-to-accommodate claim at summary judgment by simply asserting that full-time presence is an essential function. The employer must present evidence explaining why the core duties of the job cannot be performed on the requested modified schedule, and summary judgment is improper when there is a genuine dispute of material fact as to whether the employee was performing those essential functions. The court found that genuine disputes of material fact existed regarding whether full-time work was an essential function of Hostettler's position. Hostettler presented evidence—including her own testimony, a colleague's declaration, and a positive performance review from her supervisor—that she successfully performed all core duties of her job while on a part-time schedule. While her supervisor, Beasley, testified that she felt 'overwhelmed,' she could not identify any specific, essential responsibilities that were not completed. The court distinguished prior cases by noting that unlike the employers in those cases, Wooster failed to tie the full-time requirement to any specific job duties that could not be accomplished on a modified schedule. To rule otherwise would allow employers to categorically refuse any accommodation involving a modified schedule, thereby undermining the ADA's purpose and its regulations, which explicitly list part-time schedules as a form of reasonable accommodation. The court also found a genuine dispute of fact existed as to whether Wooster engaged in the interactive process in good faith.

Analysis:

This decision reinforces that the 'essential functions' analysis under the ADA is a highly fact-specific inquiry that cannot be resolved by an employer's labels or preferences at the summary judgment stage. It clarifies that while an employer's judgment is a relevant factor, it is not determinative and can be rebutted by an employee's evidence that they are successfully performing their core duties with an accommodation. The ruling makes it more difficult for employers to win summary judgment in failure-to-accommodate cases by simply asserting that full-time presence is required. It signals to lower courts that they must carefully weigh competing evidence about job performance before concluding that a modified schedule is an unreasonable accommodation as a matter of law.

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