Stacy L. Deane v. Pocono Medical Center
142 F.3d 138, 1998 WL 173100 (1998)
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Rule of Law:
Under the Americans with Disabilities Act (ADA), an individual 'regarded as' having a disability is considered a 'qualified individual' if they can perform the essential functions of the employment position, with or without reasonable accommodation, not necessarily all functions of the job.
Facts:
- Pocono Medical Center (PMC) hired Stacy L. Deane as a registered nurse on the medical/surgical floor in April 1990.
- In June 1991, Deane sustained a cartilage tear in her right wrist while lifting a resistant patient, causing her to miss approximately one year of work.
- In June 1992, Deane informed PMC of her intent to return to work with restrictions, stating she was unable to lift more than 15-20 pounds or perform repetitive manual tasks, but was willing to move to another area of the hospital if accommodated.
- PMC officials, after reviewing Deane's request and her stated restrictions, determined that she was unable to return to her previous position or any other available nursing position in the hospital.
- PMC sent Deane an 'exit interview' form on August 7, 1992, and subsequently notified her by telephone on August 10, 1992, that she could not return to work because of her 'handicap.'
- Deane later accepted registered nurse positions at two different non-acute care facilities where she was employed, neither of which required heavy lifting, bathing patients, or similar strenuous tasks.
Procedural Posture:
- Stacy L. Deane filed a lawsuit against Pocono Medical Center (PMC) in federal district court, alleging violations of the Americans with Disabilities Act (ADA), the Rehabilitation Act of 1973, and the Pennsylvania Human Relations Act.
- The district court granted summary judgment in favor of PMC on all claims, ruling that Deane was neither actually disabled nor 'regarded as' disabled and, even if she were, she failed to meet the statutory definition of a 'qualified individual' with a disability.
- Deane appealed the district court's grant of summary judgment to the United States Court of Appeals for the Third Circuit.
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Issue:
Does the Americans with Disabilities Act require 'regarded as' disabled plaintiffs to demonstrate their ability to perform all functions of a position, or only the essential functions, with or without reasonable accommodation, to be considered a 'qualified individual'?
Opinions:
Majority - Becker, Chief Judge
No, the Americans with Disabilities Act (ADA) requires 'regarded as' disabled plaintiffs to prove their ability to perform only the essential functions of a position, with or without reasonable accommodation, to be considered a 'qualified individual.' The plain and unambiguous language of 42 U.S.C. § 12111(8) defines a 'qualified individual with a disability' as one who 'with or without reasonable accommodation, can perform the essential functions' of the job. The phrase 'with or without reasonable accommodation' refers directly to 'essential functions,' and the Act does not distinguish between actual or perceived disabilities in terms of this threshold qualification. Legislative history further supports that the ADA focuses on 'essential functions' to prevent disqualifying individuals for inability to perform non-essential or marginal duties. The court also determined that Deane adduced sufficient evidence to create genuine issues of material fact regarding whether PMC misperceived her as being disabled and whether lifting is an essential function of nursing at PMC, making summary judgment inappropriate. An innocent misperception of an individual’s impairment, if it leads an employer to believe the individual is substantially limited in a major life activity (like working in a broad range of jobs), can satisfy the 'regarded as' prong, regardless of whether the employer was motivated by myth or fear. Deane presented evidence of PMC's confusion regarding her capacity, lack of thorough evaluation, and vocational expert testimony indicating that PMC's perceived limitations would significantly restrict her ability to work in a class or broad range of jobs. Furthermore, the court found that PMC's job description and judgment were not conclusive evidence of essential functions, emphasizing that 'essential functions' is a factual determination based on all relevant evidence, and Deane offered conflicting evidence, such as the Department of Labor's job descriptions and PMC's team lifting approach. Finally, Deane easily established the third prong of her prima facie case (adverse employment action due to disability) given PMC's direct statement of termination due to her 'handicap.' The case is remanded for further proceedings, with the court highlighting the importance of employer-employee communication in the interactive process for accommodations.
Dissenting - Greenberg, Circuit Judge
No, a person who is not actually disabled, and who concedes this fact (as Deane did), cannot demand a reasonable accommodation from an employer under the ADA. While the ADA protects individuals who are 'regarded as' disabled from discrimination, it does not mean that an employee without an actual disability can claim they need an accommodation and then sue when the employer takes them at their word but declines to provide it. Congress did not enact the ADA to allow non-disabled persons to demand accommodations. Therefore, the factual disputes concerning whether PMC misperceived Deane as disabled or whether heavy lifting is an essential function are not material to the outcome. Since Deane is not actually disabled, she has no statutory right to an accommodation, regardless of the employer's perceptions or the nature of job functions. An employer can determine the essential elements of a job without concern that its determination might be challenged under the ADA by a person who is not actually disabled. Thus, the district court's grant of summary judgment should be affirmed.
Analysis:
This case significantly clarifies the scope of the ADA for 'regarded as' disabled plaintiffs, affirming that they are held to the same 'essential functions' standard as actually disabled individuals. The ruling underscores that an employer's misperception, even if not based on malice or stereotype, can trigger ADA protection if it leads to a belief of a substantial limitation on a major life activity. It also reinforces that the determination of 'essential functions' is a fact-intensive inquiry, requiring courts to look beyond formal job descriptions to 'all relevant evidence.' The court also implicitly warns employers that failing to engage in an interactive process with an employee requesting accommodation, even one regarded as disabled, carries legal risks.
