Equal Employment Opportunity Commission v. LHC Group, Inc.
773 F.3d 688
| 5th Cir. | 2014Background
- EEOC enforcing the ADA on Kristy Sones against LHC Group, Inc.
- Sones, a registered nurse, allegedly was terminated after a seizure and disability-related challenges.
- There is a dispute whether she was promoted to Team Leader or merely cross-trained at termination.
- Driving is a central function for Field Nurse duties; Team Leader duties focus more on scheduling and office-based tasks.
- District court granted summary judgment for LHC; this court reverses in part and remands for further proceedings.
- Key issue centers on whether Sones was qualified for the position and whether she could be accommodated.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper prima facie standard for disability discrimination | Zenor formulation (disability, qualified, adverse action) | Chevron Phillips/Burch line requiring nexus and replacement/less favorable treatment | Zenor formulation governs prima facie case |
| Whether Sones was a qualified individual for Team Leader or Field Nurse | Could perform essential functions or be accommodated | Driving/essential functions cannot be accommodated; no feasible accommodation | Genuine disputes on Team Leader qualification and accommodations; Field Nurse clearly not qualified as a matter of law; remand for qualification analysis |
| Was driving an essential function for the Team Leader position? | Driving could be accommodated via rides/public transit | Driving is essential and not reasonably accommadable | Fact dispute; possible accommodation for Team Leader; driving essential for Field Nurse not disputed; remand on qualification issue |
| Whether LHC failed to engage in the interactive process for accommodations | Sones requested help with computers/passwords; supervisor walked away | No interactive process showed | Genuine dispute on whether interactive process occurred; district court erred |
| Nexus between disability and termination (discriminatory discharge) | Statements/charges indicate disability was a motivating factor | Termination based on performance, not disability | Evidence raises genuine dispute on whether disability was a motivating factor; summary judgment improper on discriminatory-discharge claim |
| Whether EEOC failed to prove pretext | LHC’s reasons contradicted by pre-seizure performance deficiencies | Evidence supports legitimate performance-based termination | Pretext not shown, but mixed-motive theory survives due to statements; issues remain material for trial on discriminatory discharge |
Key Cases Cited
- Zenor v. El Paso Healthcare Sys., Ltd., 176 F.3d 847 (5th Cir. 1999) (elements: disability, qualified, adverse action; nexus applicable to prima facie case)
- Chevron Phillips Chem. Co. v. EEOC, 570 F.3d 606 (5th Cir. 2009) (discusses burden-shifting and interactive-process concepts)
- Burch v. Coca-Cola Co., 119 F.3d 305 (5th Cir. 1997) (formulation on prima facie discrimination in ADA context)
- Laxton v. Gap Inc., 333 F.3d 572 (5th Cir. 2003) (relevance of mixed-motive theory and pretext considerations)
- Pinkerton v. Spellings, 529 F.3d 513 (5th Cir. 2008) (discrimination may be a motivating factor even without sole cause)
- Machinchick v. PB Power, Inc., 398 F.3d 345 (5th Cir. 2005) (mixed-motive framework for discrimination)