Equal Employment Opportunity Commission v. Vicksburg Healthcare, L.L.C.
663 F. App'x 331
| 5th Cir. | 2016Background
- Beatrice Chambers, a nurse at River Region, tore her rotator cuff, had surgery in 2011, and received 12 weeks of FMLA leave; she sought a two‑week extension which was denied.
- Her physician cleared her to return to work with restrictions: "light work" and no lifting/pushing/pulling over 10 pounds.
- River Region terminated Chambers as unable to perform her job duties; the day after termination she and Dr. Porter submitted temporary total disability claim forms.
- EEOC sued River Region under the ADA for failure to provide a reasonable accommodation and wrongful termination.
- District court granted summary judgment for River Region, reasoning Chambers’ disability benefit claim conflicted with ADA ‘‘qualified’’ status under Cleveland v. Policy Management.
- The Fifth Circuit reversed and remanded, holding the EEOC’s explanation (that reasonable accommodation could enable Chambers to perform essential functions) was sufficient to avoid Cleveland dismissal; factual disputes precluded summary judgment on alternative defenses.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Chambers’ contemporaneous claim of temporary total disability bars ADA claim under Cleveland | Chambers (through EEOC) argued her disability‑benefits claim does not contradict an ADA claim because she could perform her job with reasonable accommodation | River Region argued the disability claim demonstrates she was not a "qualified individual" and thus Cleveland bars the ADA suit | Held for EEOC: Cleveland does not bar the action here; EEOC’s explanation that accommodation could enable her to perform essential functions is sufficient |
| Whether River Region offered and kept open a reasonable accommodation (light‑duty clerical work) | EEOC contended no valid, continuing offer was established and evidence supports that no second offer was made | River Region said it offered light‑duty work twice and Chambers rejected/failed to accept it | Held: Genuine disputes of fact exist about whether offers were made/kept open; summary judgment inappropriate |
| Whether Chambers requested an accommodation | EEOC argued submission of doctor’s restriction forms constituted a request for light duty without needing magic words | River Region argued Chambers never properly requested light duty | Held: Submission of medical clearance with restrictions can constitute a request; issue for factfinder |
| Whether lifting/pushing >10 lbs. are essential functions of her nursing job | River Region relied on job description and testimony that such exertions are essential | EEOC produced testimony suggesting those tasks are rarely required; Chambers testified she could not recall lifting >10 lbs. | Held: Whether those tasks are essential is a fact question; cannot resolve on summary judgment |
Key Cases Cited
- Cleveland v. Policy Management Sys. Corp., 526 U.S. 795 (1999) (explains when disability‑benefit claims must be reconciled with ADA "qualified" status and permits reasonable‑accommodation explanation)
- Giles v. Gen. Elec. Co., 245 F.3d 474 (5th Cir. 2001) (recognizes that asserting reasonable accommodation can reconcile disability benefit claims with ADA qualification)
- McClaren v. Morrison Mgmt. Specialists, Inc., 420 F.3d 457 (5th Cir. 2005) (applies Cleveland and requires sufficient explanation for apparent inconsistency)
- LHC Grp., Inc. v. EEOC, 773 F.3d 688 (5th Cir. 2014) (standard for summary judgment and analysis of "essential functions")
- Reed v. Petroleum Helicopters, Inc., 218 F.3d 477 (5th Cir. 2000) (distinguishes cases where specific factual statements supporting disability benefits must be explained when inconsistent with ADA claims)