Maryanne Grande v. Saint Clare’s Health System (076606) (Morris County and Statewide)
164 A.3d 1030
| N.J. | 2017Background
- Maryanne Grande, an R.N. employed by Saint Clare’s (2000–2010), suffered multiple work-related shoulder and cervical injuries and intermittent long absences; she returned to light duty and underwent a functional capacity evaluation (FCE).
- The hospital’s 2008 Job Analysis listed certain lifting tasks (e.g., frequently lifting 50 lbs. waist-to-chest) as essential for R.N. positions; KCI’s FCE reported Grande could only perform some lifting functions occasionally and recommended limits/assistance.
- Grande’s treating physician initially cleared her to return to full duty, then issued limited restrictions “per FCE”; after termination he later cleared her for full duty (that clearance postdated the firing).
- Saint Clare’s terminated Grande shortly after the FCE, stating her perceived disability prevented safe performance; Grande sued under New Jersey’s Law Against Discrimination (LAD) alleging disability and perceived-disability discrimination.
- Trial court granted summary judgment for Saint Clare’s; Appellate Division reversed as to material factual disputes; New Jersey Supreme Court affirmed in part, remanding for trial because genuine issues of material fact exist regarding essential functions, reasonableness of the employer’s safety conclusion, and accommodation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether this is a direct‑evidence case | Grande: Saint Clare’s admitted it fired her for perceived disability, so direct evidence shifts burden to employer | Saint Clare’s: its admission does not show hostility or animus toward disabled class, so framework for circumstantial evidence applies | Court: Not direct evidence—no showing of hostility toward disabled class; apply circumstantial McDonnell Douglas framework (modified for LAD) |
| Prima facie burden — ability to perform essential functions | Grande: modest showing — long employment, previously performed job, and FCE/doctor evidence create triable issues; accommodation inquiry belongs in second‑prong analysis | Saint Clare’s: absences and medical restrictions show she could not meet legitimate job expectations | Held: Grande met the modest second‑prong showing to avoid summary judgment; material disputes exist about chronicity of absences and essential functions |
| Employer’s burden when defending based on disability/safety | Grande: employer must produce competent medical/scientific evidence linking disability to probability of substantial harm; Saint Clare’s failed to consult treating physician | Saint Clare’s: relied on objective FCE and work history to reasonably conclude incapacity/hazard | Held: Employer bears burden to prove it reasonably concluded disability precluded performance or posed materially enhanced risk; record lacks conclusive expert proof, so factual dispute precludes summary judgment |
| Role/timing of reasonable accommodation | Grande: accommodation issue relevant and employer did not adequately explore accommodations | Saint Clare’s: asserted no reasonable accommodation existed for lifting/safety concerns | Held: Court holds accommodation analysis belongs in second prong of prima facie case (employee shows ability with/without accommodation); employer may rebut by proving accommodation unreasonable — factual record here undeveloped and for trial |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (framework for circumstantial disparate‑treatment claims)
- Jansen v. Food Circus Supermkts., Inc., 110 N.J. 363 (1988) (employer bears burden to prove safety justification and probability of substantial harm when disability motivates firing)
- Andersen v. Exxon Co., 89 N.J. 483 (1982) (employer must have objectively reasonable basis; caution against cursory medical reports)
- Zive v. Stanley Roberts, Inc., 182 N.J. 436 (2005) (prima facie second‑prong is a modest showing when plaintiff performed job prior to termination)
- Bergen Commercial Bank v. Sisler, 157 N.J. 188 (1999) (distinguishing direct‑evidence and circumstantial proof; causation standard)
- Greenwood v. State Police Training Ctr., 127 N.J. 500 (1992) (employer may not rely on subjective or conclusory medical reports for safety defense)
- Clowes v. Terminix Int'l, Inc., 109 N.J. 575 (1988) (elements of prima facie discriminatory discharge)
- Deane v. Pocono Med. Ctr., 142 F.3d 138 (3d Cir. 1998) (factfinder—not job description alone—decides whether heavy lifting is essential for an R.N.)