Jimmy Mathis v. City of Red Bank, 657 F. App'x 557

Jimmy Mathis worked for the City of Red Bank since 1997 and became Assistant to the Public Works Director in 2002; the job evolved to include substantial outdoor duties by 2011–2012.
Mathis was diagnosed with lupus in 2012; his dermatologist (Dr. Susong) initially completed FMLA paperwork indicating Mathis needed to be indoors and might miss work during flare-ups.
The Department reorganized during Mathis’s FMLA leave; many of his prior administrative duties were reassigned and the Assistant position's work became largely outdoor by the time he attempted to return.
Mathis returned, used protective clothing (initially at his own cost, later paid by the City), but by mid‑2013 submitted a new medical statement where Dr. Susong said Mathis must work only indoors, period.
The City could not identify any vacant indoor positions for which Mathis was qualified and, relying on the doctor’s directive, laid him off in July 2013; Mathis sued under the ADA for failure to accommodate and failure to engage in the interactive process.
The district court granted summary judgment to the City; the Sixth Circuit affirmed, finding no available reasonable accommodation and no failure to engage in the interactive process in bad faith.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether City failed to provide a reasonable accommodation under the ADA	Mathis: City should have restored him to the pre‑late‑2011 Assistant job (mostly indoor) or otherwise accommodated limited sun exposure	City: Early‑2011 Assistant job still required substantial outdoor work; doctor’s 2013 directive required exclusively indoor work; no vacant indoor position fit Mathis’s qualifications	Court: No. The pre‑2011 job still had essential outdoor functions and no reasonable accommodation was available given doctor’s restriction
Whether employer failed to engage in the ADA’s interactive process in good faith	Mathis: City should have initiated and sought accommodations starting March 2012 when it knew of his condition	City: Mathis sought only FMLA leave in 2012 and did not request an accommodation; employer’s duty to engage arises after an employee requests accommodation or shows need	Court: No. Employee did not request accommodation in 2012; City acted appropriately once given clear medical restrictions in 2013

Keith v. Cty. of Oakland, 703 F.3d 918 (6th Cir. 2013) (elements for ADA prima facie case)
Hedrick v. W. Reserve Care Sys., 355 F.3d 444 (6th Cir. 2004) (plaintiff’s burden to propose reasonable accommodation)
Burns v. Coca‑Cola Enterps., Inc., 222 F.3d 247 (6th Cir. 2000) (plaintiff must show ability to perform essential functions with or without accommodation)
Hoskins v. Oakland Cty. Sheriff’s Dep’t, 227 F.3d 719 (6th Cir. 2000) (evidence showing whether a job function is essential)
Kleiber v. Honda of Am. Mfg., Inc., 485 F.3d 862 (6th Cir. 2007) (interactive process requires good‑faith participation by both parties)
Cassidy v. Detroit Edison Co., 138 F.3d 629 (6th Cir. 1998) (employer not required to reallocate essential functions)
Arthur v. Am. Showa, Inc., [citation="625 F. App'x 704"] (6th Cir. 2015) (no need to decide interactive process failure when no vacancy existed)
Ozlowski v. Henderson, 237 F.3d 837 (7th Cir. 2001) (similar rule regarding interactive process and vacant positions)