119 F. Supp. 3d 807
W.D. Tenn.2015Background
- Andrea Mosby Meachem, an Attorney 3 at Memphis Light, Gas & Water (MLGW), requested an accommodation in January 2013 to work from home/bed during a high‑risk pregnancy and bed rest after surgery. The ADA Committee (and supervisor Cheryl Patterson) denied the request; Plaintiff received notice Jan. 30, 2013.
- Plaintiff used accrued sick leave and short‑term disability through March 31, 2013; physicians supported her ability to work remotely but later provided notes restricting work and supporting FMLA leave.
- During the accommodation period Plaintiff’s law license was suspended for nonpayment of bar fees—a payment process the employer handled and for which Plaintiff alleges the employer’s clerical error was responsible. Suspension was publicized and later discussed in a June 2013 letter.
- Upon return, Plaintiff received a 2013 performance appraisal with negative commentary (including alleged adverse media rating). Plaintiff alleges the appraisal comments and reassignment of matters were retaliatory and connected to her accommodation request and protected activity.
- The court evaluated ADA failure‑to‑accommodate, Tennessee Human Rights Act (pregnancy discrimination), and retaliation claims, and denied defendant’s motion for summary judgment, finding multiple factual disputes for a jury.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Failure to accommodate (ADA): whether Plaintiff was a "qualified individual" able to perform essential functions with accommodation | Meachem: physical presence is not essential; she could perform duties remotely with electronic file access; license suspension resulted from defendant’s clerical error | MLGW: physical presence is essential for certain functions; mental impairment and suspended license made her unqualified | Court: plaintiff met prima facie case; material disputes (essential functions, cause of license suspension, onset/severity of mental symptoms) preclude summary judgment |
| Undue hardship (employer defense) | Meachem: remote access/scanning would be minimal cost; MLGW had allowed telework before | MLGW: coverage by other attorneys and file delivery would impose significant difficulty/expense | Court: defendant offered only conclusory hardship claims; undue hardship unresolved—jury question |
| Reasonableness of employer’s offered accommodation (leave/benefits) | Meachem: employer’s offered options were not necessarily reasonable; she requested remote work instead of extended leave | MLGW: offered accommodations were reasonable | Held: whether offered accommodation was reasonable is a fact question for the jury |
| Retaliation (ADA & THRA): causal link between protected activity and adverse actions (appraisal, reassignments) | Meachem: timing plus content of 2013 appraisal, lack of prior notice/opportunity to respond, and other evidence support causation and pretext | MLGW: negative comments predated 2013; temporal proximity alone is insufficient; reassignment was legitimate (conflict concerns) | Court: plaintiff presented sufficient evidence (timing + additional indicia) to create a genuine dispute on causation, adverse action, and pretext—jury to decide |
Key Cases Cited
- Anderson v. Liberty Lobby, 477 U.S. 242 (1986) (summary judgment standard requires more than a scintilla of evidence)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (nonmovant must show more than metaphysical doubt)
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (party opposing summary judgment must present concrete evidence)
- Reeves v. Sanderson Plumbing Prods., 530 U.S. 133 (2000) (courts must not make credibility determinations at summary judgment)
- Monette v. Elec. Data Sys. Corp., 90 F.3d 1173 (6th Cir. 1996) (McDonnell Douglas framework discussed in ADA cases)
- Kleiber v. Honda of Am. Mfg., Inc., 485 F.3d 862 (6th Cir. 2007) (direct‑evidence ADA failure‑to‑accommodate analysis and burdens of proof)
- EEOC v. Ford Motor Co., 782 F.3d 753 (6th Cir. 2015) (assessment whether functions can be performed remotely is fact intensive)
- Rorrer v. City of Stow, 743 F.3d 1025 (6th Cir. 2014) (essential‑function and undue‑hardship inquiries often unsuitable for resolution on summary judgment)