Field v. MedLab Ohio, Inc.
2012 Ohio 5068
Ohio Ct. App.2012Background
- Field sued MedLab under Ohio disability-discrimination statute for alleged hostile treatment due to a perceived mental impairment from alcoholism.
- MedLab transferred Field to a smaller, less stressful territory and later terminated her for poor performance and client losses.
- Field admitted she never disclosed alcoholism or a mental disorder to MedLab or its management.
- MedLab argued termination was based on objective performance problems and client losses, not disability.
- The trial court granted summary judgment for MedLab; Field appeals challenging the adequacy of the prima facie disability-discrimination showing.
- Court analyzes whether Field was regarded as having a disability; concludes no genuine issue of material fact shows MedLab regarded Field as disabled.
- Evidence shows knowledge of hospitalization alone does not prove consideration of a disability; transfer/termination preceded any hospitalization awareness.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Field can prove MedLab regarded her as disabled. | Field (Field) contends MedLab regarded her as having a mental impairment related to alcoholism. | MedLab argues it discharged/relocated based on performance, not disability. | No genuine issue; summary judgment affirmed on regard-as-disability claim. |
Key Cases Cited
- Dresher v. Burt, 75 Ohio St.3d 280 (1996-Ohio-107) (summary-judgment burden on moving party)
- Zivich v. Mentor Soccer Club, Inc., 82 Ohio St.3d 367 (1998-Ohio-389) (de novo review of summary-judgment standard)
- Hayes v. Cleveland Pneumatic Co., 92 Ohio App.3d 36 (1993-Ohio-) (disability definition under Ohio law; alcoholism covered)
- Hazlett v. Martin Chevrolet, Inc., 25 Ohio St.3d 279 (1986-Ohio-) (addiction as covered disability; cannot discharge for disability)
- Landefeld v. Marion Gen. Hosp., 994 F.2d 1178 (6th Cir.1993) (employer’s knowledge of disability challenged; reaction to misconduct)
- Wysong v. The Dow Chemical Co., 503 F.3d 441 (6th Cir.2007) (regarded-as claim lacking where direct evidence of labeling as drug user not shown)
- Hammon v. DHL Airways, Inc., 165 F.3d 441 (6th Cir.1999) (employer notice of disability required; mere anxiety not enough)