Joseph White v. Interstate Distributor Company, 438 F. App'x 415

White was hired as maintenance tech I in July 2008, a role requiring heavy truck repair and lifting up to 80 lbs, with substantial lifting duties a third of the time.
He sustained a leg fracture from a motorcycle accident on July 26, 2009, initiating FMLA leave and communications with HR about return and accommodations.
On September 18, 2009, White received a notice inviting him to participate in an interactive process regarding return to work and accommodations.
After medical review, Dr. Cook imposed temporary restrictions for 1–2 months: no lifting over 20 lbs or no weight lifting 60–100% of the time, and no tire/transmission work during restrictions.
White returned on October 20, 2009, but there were no available positions that accommodated his restrictions, according to Bernard and Johnston.
Interstate terminated White on October 21, 2009, concluding he could not perform the tech duties under his restrictions, leaving no viable accommodation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether White is 'otherwise qualified' with accommodations.	White contends accommodations could enable him to perform the job.	Interstate asserts no accommodation could enable White to meet essential functions.	White not otherwise qualified; no feasible accommodation exists.
Whether any reasonable accommodation existed for White.	Decommissioning trucks could be a reasonable accommodation.	Decommissioning is not a full-time, funded position and not a viable accommodation.	No reasonable accommodation was available.
Whether Interstate engaged in a proper interactive process.	Interstate failed to engage in adequate interactive process.	Interstate did engage in interactive discussions over the phone.	Interstate satisfied the interactive-process requirement.
Whether White is protected under a 'regarded as disabled' theory.	Interstate regarded him as disabled.	Even if regarded as disabled, White's impairment is transitory.	No protection; impairment is transitory under the ADA.

Monette v. Elec. Data Sys. Corp., 90 F.3d 1173 (6th Cir. 1996) (defines 'otherwise qualified' standard under ADA)
Jakubowski v. Christ Hosp., Inc., 627 F.3d 195 (6th Cir. 2010) (essential functions are 'fundamental job duties')
Willard v. Potter, 264 F. App’x 485 (6th Cir. 2008) (reassignment requires a vacant, funded position)
Hoskins v. Oakland Cnty. Sheriff’s Dept., 227 F.3d 719 (6th Cir. 2000) (reasonable accommodation burden and process standards)
Kleiber v. Honda of Am. Mfg., Inc., 485 F.3d 862 (6th Cir. 2007) (interactive process and reasonable accommodation analysis)
Wilkerson v. Shinseki, 606 F.3d 1256 (10th Cir. 2010) (interactive process can be satisfied by phone discussions)
Connolly v. Entex Information Servs., Inc., 27 F. App’x 876 (9th Cir. 2001) (no mandatory in-person meeting requirement for interactive process)
Trout v. Aerospace Testing Alliance, 303 F. App’x 272 (6th Cir. 2008) (appellate note on lack of good faith in interactive process)
Denczak v. Ford Motor Co., 215 F. App’x 442 (6th Cir. 2007) (evidence standards for reasonable accommodation)
Breitfelder v. Leis, 151 F. App’x 379 (6th Cir. 2005) (accommodations not required to convert duties into permanent positions)
Brown v. Chase Brass & Copper Co., 14 F. App’x 482 (6th Cir. 2001) (de minimis or non-permanent accommodations not required as full-time reassignment)