Jeffrey Jessup v. Barnes Group, Inc., 23 F.4th 360

Background

Jessup, a Barnes Group employee, took approved medical leave for anxiety/depression after an October 2016 panic attack and returned to work April 1, 2017.
After returning he alleges demotion-like reassignment, a midyear $2M quota increase, a negative performance rating, and derogatory internal remarks about his fitness for duty.
On July 19, 2017 Jessup suffered another panic attack, sought additional leave, and Barnes denied the requested leave and instructed him to return by August 24; later leave requests and communications followed.
Barnes’ counsel sent a November 17, 2017 letter stating Barnes was terminating Jessup; Jessup retained company devices and access and later obtained a January 9, 2018 medical clearance to return to work. Barnes sent a January 17, 2018 letter confirming termination effective November 17, 2017 (backdated Jan. 8).
Jessup sued under the ADA for wrongful termination, failure to accommodate, and hostile work environment. The district court granted summary judgment for Barnes, concluding Jessup was not a "qualified individual" because his complaint and deposition admitted he had been "fully and completely disabled and unable to work" since his July 2017 relapse.
On appeal the Fourth Circuit affirmed: it held Jessup’s prior admissions were binding (defeating the qualified-individual element for the termination and accommodation claims) and, independently, that the evidence did not show severe or pervasive harassment sufficient to support an ADA hostile-work-environment claim.

Issues

Issue	Jessup's Argument	Barnes' Argument	Held
Whether Jessup was a "qualified individual" under the ADA for wrongful termination and failure-to-accommodate claims	Jessup contends he was able to perform essential functions (pointing to a January 2018 return-to-work week and medical clearance)	Barnes relies on Jessup’s complaint and deposition admissions that he was "fully and completely disabled and unable to work" since July 2017	Court: Admissions in pleadings/deposition are deliberate and binding — Jessup is not a qualified individual; summary judgment affirmed
Whether Jessup’s later declaration and medical certification create a genuine factual dispute overcoming his prior admissions	The January 2018 medical release and Jessup’s sworn declaration that he returned to work create a triable issue	Prior clear, unambiguous admissions control; contradictory affidavit disregarded under Fourth Circuit precedent	Court: Contradictory post-deposition affidavit and evidence do not overcome binding admissions (Halperin); no genuine dispute as to qualification
Whether Barnes’ alleged conduct created an ADA hostile work environment (severity/pervasiveness; and whether Jessup’s qualification matters)	Jessup points to reassignment, quota increase, negative rating, management comments/emails and behind-the-scenes efforts to build a discharge case as cumulatively hostile	Barnes argues the acts were not severe or pervasive; many communications were unknown to Jessup and thus irrelevant to objective hostility	Court: Even cumulatively the conduct of which Jessup was aware was not sufficiently severe or pervasive to be objectively hostile; summary judgment affirmed

Key Cases Cited

Wilson v. Dollar Gen. Corp., 717 F.3d 337 (4th Cir.) (defines requirement that plaintiff be a "qualified individual" under the ADA)
Halperin v. Abacus Tech. Corp., 128 F.3d 191 (4th Cir.) (prior admissions and contradictions with later affidavits in summary-judgment context)
Fox v. Gen. Motors Corp., 247 F.3d 169 (4th Cir.) (elements and objective/subjective standard for ADA hostile-work-environment claims)
Boyer-Liberto v. Fontainebleau Corp., 786 F.3d 264 (4th Cir.) (an isolated but extremely serious incident can suffice for hostile-work-environment claim)
Thompson v. Gold Medal Bakery, Inc., 989 F.3d 135 (1st Cir.) (illustrative holding that sworn statements of inability to work defeat ADA qualified-individual showing)
Butts v. Prince William Cnty. Sch. Bd., 844 F.3d 424 (4th Cir.) (pleading admissions bind parties in litigation)