Danny Delaval v. PTech Drilling Tubulars, LLC, 824 F.3d 476

Background

Delaval, a machinist at PTech, missed work from March 17–25, 2014 for medical testing (kidney stones, enlarged spleen) and emailed an owner (Dallas) about his condition and planned absence.
PTech terminated Delaval on March 27, 2014 under an attendance policy that permits immediate dismissal for failing to show up >3 consecutive days without notifying a supervisor.
Parties dispute communications during the absence: Delaval claims ongoing contact and that he provided medical documents to office staff; PTech supervisors say Delaval failed to respond to attempts to reach him and did not produce a doctor’s note when requested.
Delaval sued under the ADA (disability discrimination and failure-to-accommodate), ADEA, and Texas law; he abandoned age and state-law claims and appealed only ADA claims after the district court granted summary judgment for PTech.
The district court granted summary judgment on discrimination and (sua sponte) on failure-to-accommodate; the Fifth Circuit affirmed, assuming arguendo Delaval was disabled but concluding he failed to rebut PTech’s nondiscriminatory reason and that he obstructed the interactive process.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did PTech terminate Delaval because of a disability (ADA discrimination)?	Delaval says emails and his testimony show PTech knew of his medical condition and effectively authorized his absence, so termination was disability-based.	PTech says it lawfully terminated him for violating the attendance policy; emails do not show discriminatory motive.	Court: No ADA discrimination — Delaval failed to present substantial evidence that PTech's attendance-based reason was pretextual.
Did Delaval request a reasonable accommodation (leave) under the ADA?	Delaval contends he requested (and was granted) time off for medical testing and that termination withdrew that accommodation.	PTech says, at most, Delaval requested a short, discrete absence; he then failed to maintain communication and sought indefinite leave, which is unreasonable.	Court: Assumed an accommodation request but did not decide; instead found Delaval hindered the interactive process.
Did Delaval’s actions break down the interactive process (failure-to-accommodate)?	Delaval claims he provided medical documentation to staff and did not refuse to cooperate.	PTech says it asked for a doctor’s note and corroboration of whereabouts; Delaval never produced timely documentation, causing the breakdown.	Court: Held Delaval caused the breakdown by failing to provide requested medical evidence; summary judgment for PTech affirmed.
Was the district court’s sua sponte grant of summary judgment on accommodation procedurally improper?	Delaval argues lack of notice and no briefing on that claim below.	PTech and court note district-court-level findings and that Delaval offered no additional evidence or motion for reconsideration.	Court: Any lack of notice was harmless; Delaval offered no further evidence and did not show prejudice.

Key Cases Cited

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes burden-shifting framework for circumstantial discrimination claims)
EEOC v. LHC Grp., Inc., 773 F.3d 688 (5th Cir. 2014) (summary-judgment standards and ADA prima facie elements)
Burton v. Freescale Semiconductor, Inc., 798 F.3d 222 (standard for showing pretext at summary judgment)
Griffin v. United Parcel Serv., Inc., 661 F.3d 216 (interactive process and employee-caused breakdown doctrine)
Holtzclaw v. DSC Commc’ns Corp., 255 F.3d 254 (appellate affirmance may rest on any record-supported ground)
Rogers v. Int’l Marine Terminals, Inc., 87 F.3d 755 (indefinite leave need not be provided as a reasonable accommodation)
Prevo’s Family Mkt., Inc. v. EEOC, 135 F.3d 1089 (employer may require documentation to substantiate medical condition)
Leatherman v. Tarrant Cnty. Narcotics Intelligence & Coordination Unit, 28 F.3d 1388 (procedural rules for sua sponte summary judgment without notice)