Cameron Cooper v. Dolgencorp, LLC, 93 F.4th 360

Cameron Cooper, diagnosed with Tourette Syndrome with coprolalia (involuntary use of profanity and racial slurs), was employed by Coca-Cola Consolidated, Inc. (CCCI) as a delivery merchandiser, a role requiring excellent customer service to CCCI clients.
CCCI received complaints from customers about Cooper's offensive language, prompting the company to provide various workplace accommodations over the years, including changing his route and, eventually, proposing a transfer to a non-customer-facing warehouse position.
Following the transfer and a reduction in pay, Cooper resigned and subsequently filed an ADA lawsuit alleging disability discrimination (failure to accommodate), constructive discharge, and related claims (dropping retaliation and failure-to-engage-in-the-interactive-process by summary judgment).
The district court granted summary judgment to CCCI, finding Cooper was neither qualified for his original position without accommodation nor entitled to his preferred accommodations.
On appeal, Cooper contested summary judgment on his failure-to-accommodate and constructive discharge ADA claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Qualification without Accommodation	Cooper could perform job without accommodation despite tics.	Cooper could not provide required customer service; slurs were decipherable.	Cooper was not otherwise qualified to perform role without accommodation.
Reasonable Accommodation	CCCI should have assigned him to non-customer-facing delivery route.	No such non-customer-facing routes were vacant; warehouse reassignment reasonable.	Plaintiff did not show preferred routes were available; warehouse was reasonable.
Constructive Discharge	Transfer to warehouse was an intolerable demotion forcing resignation.	Transfer was an attempt to reasonably accommodate, not force termination.	Plaintiff presented no evidence CCCI intended to force resignation.

Monette v. Elec. Data Sys. Corp., 90 F.3d 1173 (6th Cir. 1996) (articulating the basic ADA accommodation standards and burdens)
Kleiber v. Honda of Am. Mfg., Inc., 485 F.3d 862 (6th Cir. 2007) (direct evidence test for ADA failure-to-accommodate claims)
Cassidy v. Detroit Edison Co., 138 F.3d 629 (6th Cir. 1998) (employer may reassign employee to lower graded position if comparable option unavailable)
Savage v. Gee, 665 F.3d 732 (6th Cir. 2012) (constructive discharge standards for intolerable work conditions)
Blachet v. Charter Commc’ns, LLC, 27 F.4th 1221 (6th Cir. 2022) (failure-to-accommodate claims involve direct evidence)