Annie Boone v. Board of Governors of the Univ, 19-1758

Boone was a UNC employee who sought accommodations for a claimed disability and requested either unpaid leave or light-duty work.
She took 12 weeks of FMLA leave, then additional unpaid leave; she did not return to work until several weeks after FMLA expired and was later terminated after roughly six months of absence.
Boone failed to provide medical documentation substantiating her disability to UNC and did not give full information to her primary care provider.
UNC and Boone each blamed the other for a breakdown in the interactive accommodation process; UNC relied on medical/fitness recommendations in deciding termination.
District court dismissed Boone’s ADA Title II and FMLA interference claims and granted summary judgment to UNC on her Rehabilitation Act failure-to-accommodate and FMLA retaliation claims; Boone appealed.
The Fourth Circuit affirmed the district court in all respects.

Issue	Plaintiff's Argument	Defendant's Argument	Held
ADA Title II applicability	Boone argued UNC’s actions violated Title II	UNC argued Title II does not reach public employment discrimination	Affirmed dismissal—Title II does not provide a remedy for public employment discrimination (Reyazuddin governs)
Rehabilitation Act — failure to accommodate	Boone argued she was a qualified individual and requested reasonable accommodations (leave or light duty)	UNC argued Boone failed to provide required medical documentation and proposed accommodations were unreasonable/indefinite	Summary judgment for UNC—Boone failed to show a reasonable accommodation; indefinite leave/light duty not required
FMLA interference	Boone argued UNC interfered with her right to reinstatement after FMLA leave	UNC argued Boone received full 12 weeks and did not attempt timely return; she was not entitled to restoration because she remained unable to perform essential functions	Dismissed—no interference because Boone had full FMLA leave and did not seek restoration within entitlement period
FMLA retaliation	Boone argued termination was retaliation for exercising FMLA rights	UNC offered legitimate, nonretaliatory reason: lack of availability for work and reliance on medical/fitness recommendations	Summary judgment for UNC—Boone failed to show pretext or causal link; evidence was speculative

Reyazuddin v. Montgomery Cnty., Md., 789 F.3d 407 (4th Cir. 2015) (Title II does not provide a vehicle for public employment discrimination claims)
Hannah P. v. Coats, 916 F.3d 327 (4th Cir. 2019) (elements for failure-to-accommodate under the Rehabilitation Act)
Jacobs v. N.C. Admin. Off. of the Cts., 780 F.3d 562 (4th Cir. 2015) (employer’s duty to engage in the interactive accommodation process)
Wilson v. Dollar Gen. Corp., 717 F.3d 337 (4th Cir. 2013) (indefinite leave is not a reasonable accommodation)
Carter v. Tisch, 822 F.2d 465 (4th Cir. 1987) (employer not required to assign permanent light duty that differs from essential functions)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (burden-shifting framework for discrimination/retaliation claims)
Vannoy v. Fed. Rsrv. Bank of Richmond, 827 F.3d 296 (4th Cir. 2016) (prima facie elements for FMLA retaliation)