59 F.4th 791
6th Cir.2023Background
- Haley Hrdlicka worked for General Motors for ~30 years; in 2017 she was transferred from the Sculpting Department to a new Design Academy, where relations with her new supervisor (Eko) and a coworker became strained.
- Beginning May 2019 Hrdlicka had repeated tardiness and absences, often giving generalized reasons by text (e.g., headache, "mental thing," family issues); she did not seek medical care while employed.
- After performance concerns and a mid‑year review noting attendance problems, GM issued an Attendance Letter (Aug 14, 2019) requiring a regular schedule, advance notice for absences, doctor’s notes for illnesses, and warning that continued violations could lead to discharge.
- Hrdlicka was late several times immediately after the letter and missed critical days of the summer intern program; Eko terminated her on Aug 21, 2019 for repeated violations of the Attendance Letter.
- While her open‑door appeal was pending, Hrdlicka was diagnosed (Oct–Nov 2019) with Persistent Depressive Disorder and a brain tumor (surgically removed); she then sued GM alleging ADA/PWDCRA disability discrimination and failure to accommodate, FMLA interference, ERISA §510, ADEA age discrimination, and Title VII/ELCRA sex and race discrimination.
- The district court granted summary judgment to GM on all claims; the Sixth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ADA – disability discrimination | Hrdlicka argues GM knew or should have known she was disabled (texts + meeting mentioning depression) and fired her for disability | GM argues no notice of disability before termination; legitimate reason was chronic absenteeism/tardiness | Held for GM: no prima facie notice; termination for legitimate nondiscriminatory reasons; no pretext |
| ADA – failure to accommodate | Hrdlicka sought transfer back to Sculpting as an accommodation for depression | GM contends transfer was requested to avoid coworkers/supervisor, position eliminated, and request was late | Held for GM: transfer was not a reasonable accommodation and was untimely; no interactive‑process violation |
| FMLA – interference | Hrdlicka contends her communications put GM on notice of need for FMLA leave | GM says she never gave adequate notice of a serious health condition or requested FMLA | Held for GM: notice inadequate—texts and work‑related framing did not convey request for FMLA leave |
| ERISA §510 | Hrdlicka contends denial of open‑door appeal interfered with benefit rights (timing of diagnosis suggests motive) | GM/JustUs say appeal denial relied on facts available at termination (attendance policy compliance) | Held for GM: JustUs decision based on pre‑termination facts; no evidence of specific intent to interfere |
| Age discrimination (ADEA/ELCRA) | Hrdlicka asserts adverse actions were age‑based | GM points to nondiscriminatory reasons (position eliminated, lack of skills, attendance) | Held for GM: plaintiff offered only conclusory assertions; no evidence of age motive |
| Race & sex discrimination (Title VII/ELCRA) | Hrdlicka alleges race/sex motivated denial of transfer and appeal | GM reiterates nondiscriminatory reasons for its actions | Held for GM: no evidence that race or sex motivated adverse decisions |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (framework for circumstantial discrimination claims)
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment burden)
- Anderson v. Liberty Lobby, 477 U.S. 242 (1986) (genuine‑issue standard)
- Cady v. Remington Arms Co., [citation="665 F. App'x 413"] (6th Cir. 2016) (what constitutes employer notice of disability)
- Hammon v. DHL Airways, Inc., 165 F.3d 441 (6th Cir. 1999) (employer need not speculate about disability or accommodation)
- Brenneman v. MedCentral Health Sys., 366 F.3d 412 (6th Cir. 2004) (FMLA notice adequacy)
- Kleiber v. Honda of Am. Mfg., Inc., 485 F.3d 862 (6th Cir. 2007) (elements for failure‑to‑accommodate claim)
- Smith v. Ameritech, 129 F.3d 857 (6th Cir. 1997) (ERISA §510 claim framework)
- Seeger v. Cincinnati Bell Tel. Co., 681 F.3d 274 (6th Cir. 2012) (standards for proving pretext)