Christina Jacobs v. N.C. Admin. Office of the Courts
780 F.3d 562
| 4th Cir. | 2015Background
- Christina Jacobs, a deputy clerk in New Hanover County, disclosed social anxiety disorder and requested reassignment to reduce front-counter customer service duties; her request was emailed Sept. 9, 2009.
- Jacobs experienced panic attacks while working the front counter; supervisors knew of her anxiety as early as May 2009 and she sought treatment after disclosure.
- While Tucker (the elected clerk) was on a three-week vacation, Jacobs’s leave request was denied; upon Tucker’s return Jacobs was called into a meeting and terminated immediately.
- AOC offered multiple justifications for termination (poor performance, sleeping on the job, procedural failures), many uncorroborated and inconsistently presented during litigation.
- The district court granted summary judgment for the AOC, finding Jacobs not disabled and that Tucker lacked knowledge of the accommodation request; the Fourth Circuit reversed in part and remanded for trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Jacobs disabled under the ADA? | Jacobs: social anxiety substantially limited interacting with others; expert supports disability. | AOC: records equivocal; plaintiff functioned in other social contexts so not substantially limited. | Reversed: genuine dispute exists; "interacting with others" is a major life activity and evidence supports a triable issue on substantial limitation. |
| Did Tucker know of the accommodation request before termination (causation)? | Jacobs: email to supervisors and annotated copy seen on Tucker’s desk; meeting with supervisors immediately before firing supports knowledge. | AOC: Tucker denied prior knowledge and said she read email only after meeting. | Reversed: record viewed for nonmovant supports inference Tucker knew; genuine dispute on knowledge. |
| Was termination discriminatory/ pretextual? | Jacobs: temporal proximity, inconsistent/undocumented reasons, and shifting justifications show pretext. | AOC: offered legitimate, nondiscriminatory reasons (performance, sleeping, procedure violations). | Reversed: sufficient circumstantial evidence of pretext and triable issues on discriminatory discharge. |
| Failure to accommodate / interactive process | Jacobs: requested reassignment (less front-counter time) — reasonable accommodation and AOC refused without engaging. | AOC: front-counter work is essential and accommodation unreasonable; plaintiff was poor performer. | Reversed: triable issues whether front-counter is essential, whether requested accommodation was reasonable, and whether AOC failed to engage in the interactive process. |
Key Cases Cited
- Tolan v. Cotton, 134 S. Ct. 1861 (U.S. 2014) (courts must view evidence in light most favorable to nonmoving party at summary judgment)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (burden-shifting framework for discrimination claims)
- Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (U.S. 2000) (plaintiff may show pretext and prevail by circumstantial evidence)
- Chevron U.S.A., Inc. v. Natural Res. Def. Council, 467 U.S. 837 (U.S. 1984) (deference to reasonable agency interpretations)
- Toyota Motor Mfg., Ky. Inc. v. Williams, 534 U.S. 184 (U.S. 2002) (definition of "major life activity"—context for ADA analysis)
- Summers v. Altarum Inst., Corp., 740 F.3d 325 (4th Cir. 2014) (interpreting ADAAA's broadened disability standard)
- EEOC v. Stowe-Pharr Mills, Inc., 216 F.3d 373 (4th Cir. 2000) (elements of ADA discrimination claim)