Danny Snapp v. United Transportation Union, 547 F. App'x 824

Snapp, disabled, was employed by BNSF and later terminated after an extended disability leave.
Before termination, Snapp submitted a job application letter and a physician letter referencing his ongoing disability and need for accommodations.
The district court granted summary judgment for BNSF on ADA discrimination and wrongful discharge claims.
The panel held there is a genuine dispute about whether BNSF engaged in a good faith interactive process after Snapp notified the employer of his disability and need for accommodation.
A determination that BNSF failed to engage in the interactive process could support ADA discrimination and wrongful discharge claims.
The court reversed and remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did BNSF have a duty to engage in an interactive process?	Snapp argues notification triggered mandatory interactive process.	BNSF contends no duty arose or no failure occurred.	Yes, disputed whether the interactive process occurred in good faith.
Is there a genuine dispute on whether termination was due to disability or failure to engage	Termination connected to lack of accommodation response.	Termination justified independent of accommodation issues.	Dispute precludes summary judgment on disability-discrimination theory.
Does the termination support a wrongful discharge claim given public policy?	Discharge for disability contravenes public policy against discrimination.	Justification centered on performance-related concerns unrelated to policy.	There is a genuine dispute; summary judgment improper.

Vinson v. Thomas, 288 F.3d 1145 (9th Cir. 2002) (mandatory interactive process after disability notification)
Barnett v. U.S. Air, Inc., 228 F.3d 1105 (9th Cir. 2000 (en banc)) (interactive process to clarify needs and accommodation)
Becker v. Cashman, 114 P.3d 1210 (Wash. Ct. App. 2005) (termination conflicting with public policy against discrimination)