Mark Minnihan v. Mediacom Communications Corp.
779 F.3d 803
| 8th Cir. | 2015Background
- Minnihan was a long‑time technical operations supervisor (TOS) for Mediacom; TOS duties included supervising technicians in the field, conducting quality control checks (QCs), tech ride‑alongs, responding to escalated customer calls, and being on call; Mediacom provided a company vehicle and expected TOSs to drive as part of field work (Minnihan spent at least 50% of time outside the office).
- Minnihan had three workplace seizures (Dec 2009, Mar 2010, Apr 2011) that triggered Iowa six‑month statutory driving restrictions; Mediacom intermittently accommodated him by reassigning driving duties and having others drive him.
- After the March 2010 seizure Mediacom informed Minnihan it could not permanently accommodate a driving restriction and offered non‑driving positions elsewhere; Mediacom temporarily continued accommodation until his driving clearance in Oct 2010.
- Following the April 2011 seizure Mediacom offered reassignment to a non‑driving Network Operations Center (NOC) position in Des Moines (same pay/benefits); Minnihan did not report or request leave and was terminated for unexcused absences.
- Minnihan sued under the ADAAA and Iowa Civil Rights Act alleging failure to accommodate and discrimination; the district court granted summary judgment for Mediacom, and the Eighth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether driving is an essential function of the TOS position | Minnihan: driving was not essential because Mediacom was able to accommodate him temporarily and he could perform duties without driving | Mediacom: driving is essential because job requires on‑site work, employer judged driving essential, written job description requires valid driver’s license, and accommodation caused others extra work | Driving is an essential function of the TOS position |
| Whether Minnihan was a "qualified individual" under ADAAA/ICRA | Minnihan: he could perform essential functions with reasonable accommodation (restructure TOS or FMLA) | Mediacom: he could not perform the essential function of driving during restriction and restructuring would reallocate essential functions/undue hardship | Minnihan was not a qualified individual because he could not perform the essential function of driving and restructuring was not required |
| Whether Mediacom failed to engage in the interactive process or act in good faith | Minnihan: employer did not adequately explore ways to retain him in the TOS role | Mediacom: HR and supervisors engaged over months, explored positions, provided time and information, and offered reassignment | Mediacom engaged in the interactive process in good faith and offered reasonable accommodations |
| Whether reassignment offered (NOC position) was reasonable and required | Minnihan: transfer to Des Moines was not reasonable because he could not commute under driving restriction; he also argues adverse action | Mediacom: reassignment is a valid accommodation of last resort and was offered; Minnihan declined by failing to report | Reassignment was a reasonable accommodation; Minnihan declined it and cannot show the offered position was inferior or that a comparable Ames vacancy existed |
Key Cases Cited
- Kammueller v. Loomis, Fargo & Co., 383 F.3d 779 (8th Cir. 2004) (consequence‑of‑not‑performing function analysis and distinguishing long‑term accommodations)
- Rehrs v. Iams Co., 486 F.3d 353 (8th Cir. 2007) (employer not required to reallocate essential functions; voluntary temporary accommodation does not make a function non‑essential)
- Kallail v. Alliant Energy Corporate Servs., Inc., 691 F.3d 925 (8th Cir. 2012) (summary judgment standard and ADA essential‑function factors)
- Cravens v. Blue Cross and Blue Shield of Kansas City, 214 F.3d 1011 (8th Cir. 2000) (reassignment as accommodation of last resort; interactive‑process principles)
- Summerville v. Trans World Airlines, Inc., 219 F.3d 855 (8th Cir. 2000) (a task may be essential even if performed infrequently or by others)
- Dropinski v. Douglas Cnty, Neb., 298 F.3d 704 (8th Cir. 2002) (functions inherent to written duties may be essential even if not listed)
- Fenney v. Dakota, Minn. & E. R.R. Co., 327 F.3d 707 (8th Cir. 2003) (definition of qualified individual under ADA)
- Knutson v. Schwan's Home Serv., Inc., 711 F.3d 911 (8th Cir. 2013) (employer’s judgment about essential functions is highly probative)
- E.E.O.C. v. Wal‑Mart Stores, Inc., 477 F.3d 561 (8th Cir. 2007) (elements of a prima facie ADA discrimination claim)