Hill v. Associates for Renewal in Education, Inc.
69 F. Supp. 3d 260
D.D.C.2014Background
- Hill, proceeding pro se, sues ARE under the ADA and FMLA; FMLA claim dismissed as time-barred.
- ARE is a DC-funded nonprofit; Hill was employed since 1997, later reassigned to a third-floor classroom with no elevator.
- Hill sustained a left leg amputation and uses a prosthesis; he alleges accommodations were needed due to mobility limits.
- Plaintiff alleges a September 3, 2007 accommodation request and ongoing verbal requests; ARE disputes receipt of the requests.
- Court grants in part and denies in part ARE’s summary-judgment motions; issues concern whether Hill could have performed essential functions with relocation and whether an Aide accommodation was appropriate; hostile-work-environment claim is also addressed.
- The court analyzes elements of ADA failure-to-accommodate, deferring to evidence about whether Hill requested accommodations and whether the proposed accommodations were reasonable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ADA failure to accommodate—whether Hill requested and was denied an accommodation | Hill asserts a September 3, 2007 written request and ongoing verbal requests. | ARE contends no receipt of an accommodation request; HR and supervisor deny receipt. | Question of receipt is a jury issue; no summary judgment on this element. |
| ADA failure to accommodate—whether relocation to a lower level would be reasonable | Relocating to a lower level would address mobility limitations. | Relocation not proven to be necessary or feasible; dispute over essential functions. | Triable issue exists; not resolved on summary judgment. |
| Hostile work environment under the ADA/FMLA | Hill alleges a hostile environment based on disability and FMLA rights. | Plaintiff provides no concrete evidence of a severe or pervasive hostile environment. | Summary judgment warranted on this claim. |
Key Cases Cited
- Aka v. Wash. Hosp. Ctr., 156 F.3d 1284 (D.C. Cir. 1998) (accommodation requirements and reasonable accommodations under the ADA)
- Edwards v. EPA, 456 F. Supp. 2d 72 (D.D.C. 2006) (interactive process and reasonableness of accommodations)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. Supreme Court 1986) (material facts; summary-judgment standard and credibility inferences)
- Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. Supreme Court 1986) (summary judgment standard and burden shifting)
- Harris v. Forklift Sys., Inc., 510 U.S. 17 (U.S. Supreme Court 1993) (standard for hostile-work-environment claim requires severe or pervasive conduct)
- U.S. Airways, Inc. v. Barnett, 535 U.S. 391 (U.S. Supreme Court 2002) (accommodations and interactive process; relation to disabilities)