Hunt v. District of Columbia, 66 A.3d 987

Hunt, a former DC DOC Sergeant, alleges disability discrimination under DCHRA after PTSD from an inmate attack.
She returned to work in 2006, with a psychiatrist’s condition that she work only in posts with limited inmate contact.
DOC reassigned Hunt to the jail staff entrance to minimize inmate contact, excluding roll calls.
She had panic attacks; after 2006 leave, another psychiatrist letter in 2008 suggested potential employment in another field, not within the jail.
DOC discussed further limited-contact reassignment options (motor pool, records office) but clarified those roles still involved inmate contact.
No evidence Hunt pursued non-corrections employment or identified a vacant, qualified position outside the jail at the relevant time.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether DOC properly accommodated Hunt’s disability at the jail.	Hunt contends DOC failed to reasonably accommodate by allowing breaks or transfer.	DOC accommodated by placing her at the staff entrance with limited inmate contact; transfer to non-jail roles was not established as feasible.	No triable issue; accommodation was reasonable and transfer not proven feasible.
Whether DOC engaged in an interactive process to identify other positions.	Hunt argues DOC failed to engage in interactive process to find other vacant positions.	DOC engaged in discussion but Hunt did not indicate interest in non-corrections roles; no evident vacancies met her qualifications.	No triable issue; lack of communicated interest and lack of qualifying vacancies foreclose duty to reassign.
Whether Hunt can state a claim for intentional interference with contractual relations.	DOC’s actions breached the collective bargaining contract harming Hunt.	As a party to the contract, the District cannot be liable for interference.	Claim barred because defendant is a party to the contract.
Whether Hunt can state a claim for intentional infliction of emotional distress.	DOC’s conduct was outrageous and caused distress.	Comments by officials were harsh but not outrageous; Hunt could not perform essential duties and psychiatrist advised against jail environment.	Claim fails as a matter of law.

Aka v. Washington Hosp. Ctr., 332 F.3d 1289 (D.C. Cir. 1998) (reassignment as a reasonable accommodation under the ADA)
Strass v. Kaiser Found. Health Plan, 744 A.2d 1000 (D.C. 2000) (ADA integration of reasonable accommodations)
Duncan v. Washington Metro. Area Transit Auth., 345 F.3d 1110 (D.C. Cir. 2001) (plaintiff must prove qualified for position with/without accommodation)
Carr v. Reno, 23 F.3d 525 (D.C. Cir. 1994) (essential functions and reassignment concept under ADA)
McBride v. BIC Consumer Products Mfg. Co., Inc., 583 F.3d 92 (2d Cir. 2009) (burden to show vacant, funded position and qualifications; interactive process)
Donahue v. Consol. Rail Corp., 224 F.3d 226 (3d Cir. 2000) (vacancy and qualification evidence required for reassignment)
Peltier v. United States, 388 F.3d 984 (6th Cir. 2004) (reassignment consideration under ADA)
Cravens v. Blue Cross & Blue Shield of Kansas City, 214 F.3d 1011 (8th Cir. 2000) (failure to engage in interactive process evidence of bad faith)
Futrell v. Dep’t of Labor Fed. Credit Union, 816 A.2d 793 (D.C. 2003) (rigorous proof required for intentional infliction of distress)