Heidi Hostettler v. College of Wooster
895 F.3d 844
| 6th Cir. | 2018Background
- Heidi Hostettler was hired as a full‑time HR Generalist at the College of Wooster while pregnant; college had an informal policy allowing 12 weeks unpaid maternity leave for new hires.
- After taking 12 weeks, Hostettler developed severe postpartum depression and separation anxiety; her OB/GYN certified she could return on a reduced (five half days/week) schedule and likely return full time within a month or two.
- Wooster permitted a part‑time/modified schedule through June 30; disputes arose in July about returning to full time, host and supervisor met multiple times, and Hostettler offered to extend hours (e.g., to 2–3 p.m.) to transition back.
- Beasley (supervisor) fired Hostettler the day after receiving an updated certification continuing a half‑time schedule, stating she could not return to the HR Generalist position in a full‑time capacity; Hostettler’s replacement was hired months later.
- Hostettler sued under the ADA (failure to accommodate / discrimination), Title VII (sex/pregnancy discrimination), FMLA (interference and retaliation), and parallel Ohio claims; the district court granted summary judgment for Wooster, largely finding full‑time presence an essential function and that Wooster engaged the interactive process.
- The Sixth Circuit reversed and remanded, holding genuine disputes of material fact exist on disability status, whether full‑time presence was an essential function, whether Wooster engaged in the interactive process, Title VII pretext, and equitable‑estoppel/FMLA issues.
Issues
| Issue | Hostettler's Argument | Wooster's Argument | Held |
|---|---|---|---|
| Whether Hostettler is an "individual with a disability" under the ADA | Postpartum depression and separation anxiety substantially limited major life activities when active | Conditions were episodic, self‑reported, and insufficient to meet the standard | Hostettler is a disabled individual under the ADAAA's liberal construction standard (dispute of fact supports disability) |
| Whether Hostettler was "otherwise qualified" / whether full‑time work was an essential function | She performed core HR duties successfully on a modified schedule; coworkers and supervisor gave positive feedback; could increase hours to return full time | Job was listed full‑time; employer said regular full‑time attendance was required; department strained by her reduced hours | Court reversed: genuine disputes of material fact exist; full‑time presence is not per se essential and employer must tie time requirement to specific job needs |
| Whether Wooster engaged in the required interactive process | Supervisory meetings did not show meaningful consideration; Hostettler proposed hour extensions which went unanswered | Supervisor met with Hostettler multiple times and told her she needed to return full time | Reversed: record contains competing evidence about the content and adequacy of the meetings; summary judgment improper |
| FMLA eligibility / interference and retaliation; equitable estoppel | Wooster treated her leave as FMLA‑protected and Hostettler relied to her detriment; therefore Wooster is estopped from denying eligibility or benefits | Hostettler was never an eligible employee under the statute | Remanded: district court failed to decide equitable‑estoppel issues; fact questions remain on estoppel and on retaliation (linked to Title VII pretext) |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden‑shifting framework for discrimination claims)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard and genuine dispute analysis)
- Kleiber v. Honda of Am. Mfg., Inc., 485 F.3d 862 (summary judgment review in employment cases)
- Mosby‑Meachem v. Memphis Light, Gas & Water Div., 883 F.3d 595 (fact‑intensive analysis on essential functions and accommodations)
- EEOC v. Ford Motor Co., 782 F.3d 753 (regular, in‑person attendance often essential but requires factual showing)
- Williams v. AT&T Mobility Servs., 847 F.3d 384 (attendance essential where job duties cannot be performed remotely)
- Demyanovich v. Cadon Plating & Coatings, L.L.C., 747 F.3d 419 (standards for proving pretext)
- Dobrowski v. Jay Dee Contractors, Inc., 571 F.3d 551 (equitable estoppel can apply to FMLA eligibility and benefits)
- Mosley Martinez v. Cracker Barrel Old Country Store, Inc., 703 F.3d 911 (direct‑evidence approach when termination springs from accommodation decision)