Jakubowski v. Christ Hospital, Inc., 627 F.3d 195

Jakubowski, an Asperger's-diagnosed medical resident, was terminated from Christ Hospital after remediation-era concerns about communication and patient interaction.
Christ Hospital identified communication with colleagues and patients as essential functions for a resident and argued Jakubowski could not perform them adequately.
Jakubowski proposed accommodations focused on knowledge/understanding of his condition but did not detail how these would improve patient interaction.
Discovery revealed potential accommodations and remediation programs, plus expert opinions suggesting broader remediation options; hospital argued such options would be resource-intensive and potentially impact patient care.
District court granted summary judgment for Christ Hospital; court of appeals affirming the grant on appeal.
Court analyzes ADA/Rehabilitation Act claims, focusing on whether Jakubowski is an otherwise qualified individual with reasonable accommodations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Jakubowski is an otherwise qualified individual with reasonable accommodation	Jakubowski can perform essential functions with accommodations for communication	Jakubowski cannot meet essential functions even with proposed accommodations	Yes, not qualified with proposed accommodations at issue
Whether the proposed accommodations were reasonable	Accommodations addressing all essential functions were proposed	Accommodations were insufficient or impractical	Accommodations proposed did not address key functions; not reasonable
Whether the interactive accommodation process was undertaken in good faith	Hospital failed to fully engage; used pretextual limits	Hospital engaged in good faith, discussed accommodations, offered alternatives	Yes, hospital acted in good faith in the interactive process
Whether the district court properly applied the direct threat and undue hardship defenses			Court found no material issue precluding summary judgment on these defenses
Whether summary judgment was appropriate given the record on accommodations’ likelihood of success	Expert-proposed accommodations could remedy deficiencies	Evidence on likelihood of success too attenuated	Summary judgment appropriate; no genuine issue of material fact regarding effectiveness of accommodations

Monette v. Elec. Data Sys. Corp., 90 F.3d 1173 (6th Cir. 1996) (disability-burden to show qualified with reasonable accommodation; preconditions to suit)
Kleiber v. Honda of Am. Mfg., Inc., 485 F.3d 862 (6th Cir. 2007) (interactive process required; good faith participation)
Talley v. Family Dollar Stores of Ohio, Inc., 542 F.3d 1099 (6th Cir. 2008) (interactive process; employer not required to propose counter accommodation)
Hedrick v. W. Reserve Care Sys., 355 F.3d 444 (6th Cir. 2004) (evidence of good faith may include offering other positions)
Nance v. Goodyear Tire & Rubber Co., 527 F.3d 539 (6th Cir. 2008) (employer's good-faith participation in accommodations process)
Crocker v. Runyon, 207 F.3d 314 (6th Cir. 2000) (employer not obligated to offer accommodation where none requested)