Jones v. Walgreen Co.
679 F.3d 9
| 1st Cir. | 2012Background
- Jones worked ~20 years for Walgreens, mostly as Store Manager in Enfield, CT; she injured her knee in 2004, went on medical leave, and later sought accommodations.
- In 2005–2006 Walgreens offered and she accepted a Store Manager position in Springfield, MA, but warned of her physical limits (no ladders, limit 20-lb lifts, 8-hour shifts).
- Sept 2006–Oct 2006 Walgreens received updated medical notes restricting bending, stooping, standing, and ladders; shortly after, Jones was terminated for allegedly being unable to perform essential functions.
- Jones filed suit in 2009 alleging ADA disability discrimination and MA analogs, plus a Title VII retaliation claim related to a 2006 class action and later termination.
- District court granted summary judgment for Walgreens on both discrimination and retaliation claims; First Circuit affirmed, holding no triable issues remain regarding disability and retaliation claims.
- The court relied on employer’s written Store Manager description and evidence showing physical tasks deemed essential, and Jones’s post-2006 limitations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Store Manager duties include essential physical functions and if Jones can perform them with accommodation | Jones could perform essential functions with reasonable accommodation | Essential functions include physical tasks; Jones cannot perform them with accommodation | No triable issue; Jones cannot perform essential functions with accommodation |
| Whether Walgreens violated the ADA by failing to engage in an interactive process | Walgreens failed to engage in required interactive process | No obligation beyond determining essential functions and possible accommodations | No ADA interactive-process violation; burden not met |
| Whether Jones's termination was retaliatory beyond protected activity | Termination proximate to protected activity shows retaliation | Termination based on medical evidence of inability to perform essential functions | Claim fails; termination supported by legitimate nonretaliatory reason |
| Whether Massachusetts law parallel to ADA affects the analysis | MA law mirrors ADA; analyses should align | Analyses under MA law align with ADA analyses | Reserved; court treated MA 151B analysis as parallel to ADA for outcome |
Key Cases Cited
- Richardson v. Friendly Ice Cream Corp., 594 F.3d 69 (1st Cir. 2010) (essential functions and time on task guide Judge(s))
- Calef v. Gillette Co., 322 F.3d 75 (1st Cir. 2003) (employer’s view of essential functions; accommodation scope)
- Mulloy v. Acushnet Co., 460 F.3d 141 (1st Cir. 2006) (evidence of current incumbents informs essential functions)
- Ruiz Rivera v. Pfizer Pharm., LLC, 521 F.3d 76 (1st Cir. 2008) (prima facie disability discrimination framework)
- Laurin v. Providence Hosp., 150 F.3d 52 (1st Cir. 1998) (employer burden in accommodation context)