Adams v. Anne Arundel County Public Schools, 789 F.3d 422

Background

Andrew Adams, an assistant principal, was accused by a student of physical contact after a January 19, 2010 hallway incident; DSS (CPS) investigated and “ruled out” abuse, while the school Board conducted a separate disciplinary inquiry.
Adams took three medical leaves (totaling more than 12 weeks) for stress-related conditions diagnosed as acute stress disorder and later PTSD; his doctors recommended reassignment away from MacArthur Middle School.
While Adams was on leave the Board required three sessions with a Board-selected psychologist (Dr. Wolff), held a pre-disciplinary conference, and issued a written reprimand for escalatory physical contact.
The Board reassigned Adams to J. Albert Adams Academy (JAA), a smaller specialized school, shortly after he was cleared to return; his salary was effectively reduced later under the union pay structure by less than 1% and some discretionary bonuses became inapplicable.
Adams sued alleging FMLA interference and retaliation, ADA discrimination and retaliation, and failure to accommodate; the district court dismissed many claims and granted summary judgment to the Board on the remaining FMLA and ADA claims; the Fourth Circuit affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
FMLA interference	Board’s investigatory and disciplinary actions, mandatory exams, reprimands, and meetings interfered with the exercise of FMLA rights even though leave was not denied	Board lawfully permitted second/third medical opinions, conducted a continuing, legitimate investigation, and did not deny or curtail FMLA leave	No interference: Adams received leave (more than 12 weeks); exams and investigatory steps permitted and not shown to have discouraged leave
FMLA retaliation	Board retaliated for taking FMLA leave via reprimand, required exams, disciplinary process, and reassignment/pay effects	Actions were nondiscriminatory, supported by medical recommendations, procedural, and not materially adverse	No retaliation: lack of adverse employment actions and no causal showing; transfer followed medical advice and was not punitive
ADA discrimination/retaliation (verbal reprimands, investigation, exams)	Verbal attacks, investigation, reprimand, and required exams were discriminatory/retaliatory because they targeted his disability	These acts were routine supervisory/disciplinary measures or statutorily permitted medical inquiries and did not materially alter employment terms	No actionable discrimination/retaliation: these actions were not materially adverse to employment under ADA standards
ADA failure to accommodate (reassignment/pay reduction/timing)	Board delayed reassignment, failed to offer a reassignment without pay loss, and thereby failed to provide reasonable accommodation	Board timely effected reassignment consistent with doctors’ recommendations to a less stressful post; any pay change stemmed from collective-bargaining rules and was minimal	No failure to accommodate: reassignment was reasonable, timely, based on medical advice, and salary change resulted from neutral union rules, not discrimination

Key Cases Cited

Ragsdale v. Wolverine World Wide, Inc., 535 U.S. 81 (explains elements and purpose of FMLA interference claims)
Yashenko v. Harrah’s NC Casino Co., 446 F.3d 541 (4th Cir. 2006) (FMLA restoration and limits on absolute right to prior position)
Laing v. Fed. Express Corp., 703 F.3d 713 (4th Cir. 2013) (FMLA retaliation treated analogously to Title VII retaliation)
Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53 (retaliation requires materially adverse action to reasonable employee)
Thompson v. N. Am. Stainless, LP, 562 U.S. 170 (retaliation/adverse action principles)
US Airways, Inc. v. Barnett, 535 U.S. 391 (reasonable accommodation framework under ADA)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for discrimination claims)
Hopkins v. Balt. Gas & Elec. Co., 77 F.3d 745 (4th Cir. 1996) (reprimands not necessarily adverse employment actions)