Lori Vaughn v. Parkwest Medical Center
17-5276
| 6th Cir. | Nov 20, 2017Background
- Lori Vaughn worked as a floor nurse for Parkwest from 2003–2013 and applied to 67 nursing positions after her termination; Parkwest requires nurses to perform "Type A" physical tasks (heavy lifting up to 50 lbs occasionally).
- Vaughn sustained back and neck injuries (2005, 2010), had surgery in 2013, received temporary restrictions, was terminated after exhausting FMLA leave, and later was released without restrictions and assigned a 7% permanent impairment.
- Vaughn obtained a note from her doctor’s office stating her back pain would prevent floor-nursing, and her workers’ compensation settlement paperwork contained language (signed by counsel) indicating she believed she could not return to floor or ICU nursing.
- Parkwest rescinded consideration of Vaughn for future openings after learning of her partial disability rating and statements about inability to perform floor nursing.
- Vaughn sued under the ADA alleging failure to rehire and failure to engage in the interactive process; the district court granted summary judgment to Parkwest, finding Vaughn not shown to be qualified for essential functions.
- The Sixth Circuit reversed Parkwest’s summary judgment, held genuine disputes of material fact exist regarding essential functions and qualifications, affirmed denial of summary judgment to Vaughn, and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Vaughn was "otherwise qualified" to perform essential functions of a floor nurse under the ADA | Vaughn’s long work history as a floor nurse, recent functional capacity evaluation, and continued floor-nurse work elsewhere show she can perform essential functions (with or without accommodation) | Parkwest relied on Vaughn’s doctor/attorney statements and workers’ comp documents indicating she could not do floor nursing to show she wasn’t qualified | Reversed district court: genuine factual disputes exist about the essential functions and whether Vaughn is qualified—summary judgment inappropriate |
| What are the essential physical requirements of a floor nurse | Vaughn points to Parkwest’s written Type A requirements (lifting up to 50 lbs) which she can meet per her FCE and doctor’s agreement | Parkwest emphasizes actual job demands may exceed the Type A description (e.g., testimony that nurses sometimes must lift ~100 lbs) | Court found mixed evidence on essential functions (written description vs. testimony) creating factual issues for trial |
| Whether Vaughn’s prior workers’ comp statements/doctor note legally bar her ADA claim under Cleveland v. Policy Management | Vaughn contends she provided sufficient explanation (work history, FCE, and ongoing nursing work) to create a factual dispute despite prior statements | Parkwest argues the settlement statements and doctor note create an apparent contradiction negating qualification, invoking Cleveland to demand an explanation | Court held Cleveland does not preclude Vaughn; she offered enough explanation to create a jury question |
| Whether Parkwest failed to engage in the interactive process for accommodations | Vaughn argues Parkwest did not meaningfully explore accommodations after learning of her restrictions | Parkwest argues Vaughn never requested an accommodation or clearly signaled an accommodation was sought, so it had no duty to speculate | Court rejected failure-to-engage claim because Vaughn did not request accommodation or clearly indicate intent to seek one for the specific vacancies |
Key Cases Cited
- Ferrari v. Ford Motor Co., 826 F.3d 885 (6th Cir. 2016) (elements of ADA discrimination claim)
- Keith v. County of Oakland, 703 F.3d 918 (6th Cir. 2013) (interactive process and essential-function analysis)
- Rorrer v. City of Stow, 743 F.3d 1025 (6th Cir. 2014) (summary judgment improper where evidence on essential functions is mixed)
- Cleveland v. Policy Management Sys. Corp., 526 U.S. 795 (1999) (employee must explain apparent contradiction between benefit application and ADA claim)
- Gantt v. Wilson Sporting Goods Co., 143 F.3d 1042 (6th Cir. 1998) (employee must initiate accommodation request; employer not required to speculate)
- Griffith v. Wal-Mart Stores, Inc., 135 F.3d 376 (6th Cir. 1998) (work history can create factual dispute on qualification)
- Brickers v. Cleveland Bd. of Educ., 145 F.3d 846 (6th Cir. 1998) (29 C.F.R. § 1630.2(n)(3) factors for essential-function inquiry)