GOODRICH v. WELLPOINT INC
2:14-cv-00037
D. Me.Aug 5, 2015Background
- Goodrich, a WellPoint analyst, took a 2012–2013 medical leave for back pain.
- WellPoint approved extended leave as an ADA accommodation and later granted long-term disability (LTD) benefits.
- Goodrich returned to work in March 2013 but requested accommodations, including a reduced schedule and work-from-home options.
- WellPoint contested the scope and type of accommodations, citing a three-month on-site probation and training requirements.
- Goodrich was terminated in May 2013 after LTD was denied and medical reviews concluded he could not return to full-time work; he filed an EEOC charge later alleging disability discrimination and failure to accommodate.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Goodrich was a qualified individual with/without accommodation | Goodrich could perform essential functions with accommodations per physician’s plan | Attendance/ability to perform essential functions was not satisfied due to doctor’s recommendations | Genuine dispute as to qualification; pretext exists for termination based on conflicting evidence |
| Whether WellPoint’s termination was pretextual | Employer contradicted its reason by noting Goodrich could perform essential functions | Terminated for medical non-attendance independent of disability | Summary judgment denied on termination claim due to pretext evidence |
| Whether Goodrich exhausted administrative remedies for LTD denial | Charge scope reasonably encompassed LTD denial as part of disability discrimination | Charge did not expressly allege LTD denial; not exhausted | Denied to LTD denial claim on exhaustion grounds, but court allowed LTD denial claim to proceed via broader scope analysis |
| Whether WellPoint failed to engage in the interactive process for home-work accommodation | Employer failed to engage in interactive dialogue as required by ADA | Employer held an April 11 meeting; process was engaged | Summary judgment denied for failure-to-accommodate; genuine fact questions remain about the adequacy of the interactive process |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (establishes shifting burdens in ADA discrimination claims)
- Tobin v. Liberty Mut. Ins. Co., 433 F.3d 100 (1st Cir. 2005) (interactive-process requirements; not an excessive burden on employer)
- Freadman v. Metro. Prop. and Cas. Ins. Co., 484 F.3d 91 (1st Cir. 2007) (outline of pretext analysis and constructive accommodations)
- Romano v. U-Haul, Int’l, 233 F.3d 655 (1st Cir. 2000) (Kolstad defense requires active enforcement of non-discrimination policies)
- Soto-Feciliano v. Villa Cofresi Hotels, Inc., 779 F.3d 19 (1st Cir. 2015) (pretext and evidence-based evaluation in discrimination claims)