Henry v. United Bank
686 F.3d 50
| 1st Cir. | 2012Background
- Henry, a United Bank employee since 2006, became a credit analyst and then faced neck/spine issues beginning January 2008.
- Bank provided accommodations (ergonomic chair, modified vent) allowing Henry to work despite symptoms but her condition worsened.
- July 2008: Henry goes on leave; PCP notes bed rest and later indicates indeterminable return date; CHCP form later claims she is able to work.
- September 2008: Bank determines it cannot hold Henry's position indefinitely and terminates her on September 25 after neurologist notes.
- Henry sues for FMLA retaliation and Massachusetts Chapter 151B claims; bank moves for summary judgment and succeeds in district court, affirmed on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| FMLA retaliation claim viability | Henry asserts termination was retaliation for FMLA leave. | Bank asserts termination for legitimate, nondiscriminatory business reasons. | No pretext; legitimate reason supported summary judgment. |
| Massachusetts Chapter 151B claims viability | Henry argues discriminatory/retaliatory motive under 151B. | Bank's reasons nondiscriminatory; no pretext shown. | No triable issue; summary judgment affirmed on 151B claims. |
| Reasonableness of extended leave as accommodation | Extended, indefinite leave could be a reasonable accommodation. | Open-ended leave is not a reasonable accommodation under 151B/ADA. | Extended leave not reasonable; no duty to accommodate further. |
Key Cases Cited
- Hodgens v. General Dynamics Corp., 144 F.3d 151 (1st Cir. 1998) (McDonnell Douglas framework in employment discrimination cases)
- Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (Supreme Court 2000) (pretext framework for proving discrimination at summary judgment)
- Colburn v. Parker Hannifin/Nichols Portland Div., 429 F.3d 325 (1st Cir. 2005) (McDonnell Douglas framework in First Circuit disability cases)
- Nagle v. Acton-Boxborough Reg'l Sch. Dist., 576 F.3d 1 (1st Cir. 2009) (FMLA retaliation analysis in First Circuit context)
- Jones v. Walgreens Co., 679 F.3d 9 (1st Cir. 2012) (employer may rely on legitimate business reasons; pretext required for triable issue)