Lanier v. University of Texas Southwestern Medical Center
527 F. App'x 312
5th Cir.2013Background
- Lanier sued UT Southwestern for FMLA, ADA, and RA claims; district court granted UT Southwestern summary judgment; appellate court affirms.
- Lanier was a UTSW business analyst with rotating on-call duties requiring 15-minute response times.
- Lanier requested shorter on-call rotations due to sleep issues, not framed as a disability; requests were denied.
- In Sept 2010 Lanier informed supervisors she could not be on-call due to her father’s emergency; she swapped shifts but later discarded equipment and resigned.
- UTSW argued Lanier failed to provide proper FMLA notice and had no disability notice to trigger accommodations; the court reviewed summary judgment de novo.
- The court affirmed summary judgment on all FMLA, ADA, and RA claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did Lanier provide proper FMLA notice for leave? | Lanier attempted to take leave; text indicated on-call absence | Text did not clearly express FMLA leave to care for father | No genuine issue; notice insufficient for FMLA leave. |
| Was Lanier’s FMLA retaliation proven? | Discharged for seeking leave and EAP use | No protected activity proven; no causal link | No retaliation evidence; judgment for UTSW affirmed. |
| Did Lanier state a prima facie ADA/RA discrimination claim for failure to accommodate? | Disability (sleep disorder) required accommodation | No evidence UTSW knew of a disability or relied on it | No prima facie case; no disability notice to employer. |
| Was there ADA/RA retaliation based on disability/protected activity? | Disability/neuro sleep issues caused adverse action | No protected activity connected to separation | No causal connection shown; protection not established. |
Key Cases Cited
- Manuel v. Westlake Polymers Corp., 66 F.3d 758 (5th Cir. 1995) (standards for disability and accommodation inquiries)
- Hunt v. Rapides Healthcare Sys., LLC, 277 F.3d 757 (5th Cir. 2001) (causation and retaliation in ADA claims)
- Seaman v. CSPH, Inc., 179 F.3d 297 (5th Cir. 1999) (sleeping and thinking as major life activities under ADA/RA)
- Delano-Pyle v. Victoria Cnty., Tex., 302 F.3d 567 (5th Cir. 2002) (evidence-based assessment of prima facie case and notice)