Mia Bennett v. Hurley Medical Center, 86 F.4th 314

Background

Plaintiff Mia Bennett, a UM–Flint nursing student, completed a six‑week clinical rotation at Hurley Medical Center on floor 7E and sought permission to bring her service dog, Pistol, which alerts her to impending panic attacks so she can take medication.
Hurley initially permitted Pistol under its service‑animal policy but the dog provoked allergic reactions on the first day: a staff member required medical treatment and a patient reported symptoms; another nurse with severe dog allergies was reassigned from 7E.
Hurley conducted an individualized reassessment and concluded Pistol posed a health risk to patients and staff; it offered alternatives (crate space on another floor and scheduled/unscheduled breaks) and considered but found infeasible options (moving Plaintiff to 9E, relocating allergic patients/staff) given COVID‑19 crowding and staffing/specialty constraints.
Plaintiff could not obtain a proposed dog garment (a Shed Defender) in time and rejected the crate accommodation as inadequate for proper use of the service dog.
The district court granted summary judgment for Hurley on ADA, Rehabilitation Act, and Michigan PWDCRA claims, concluding Pistol posed a direct threat and Hurley reasonably accommodated or engaged in the process; Bennett appealed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Intentional discrimination (Title II) — causation	Bennett argued exclusion of Pistol effectively excluded her from the rotation and reflected discrimination.	Hurley argued exclusion resulted from complaints/actual allergic reactions to Pistol, not animus toward Bennett’s disability.	Court: Bennett failed to show Hurley acted "because of" her disability; no prima facie intentional discrimination.
Failure to accommodate — reasonableness of alternatives	Bennett argued Hurley should have allowed Pistol or provided other reasonable measures (e.g., move floors, separate allergic persons).	Hurley argued Pistol caused actual allergic reactions and proposed reasonable alternatives (crate, breaks); moving staff/patients or relocating Plaintiff was impracticable and risked patient care.	Court: Hurley reasonably concluded Pistol posed a direct threat; necessary mitigations were not reasonable under the circumstances; summary judgment for Hurley.
Direct‑threat individualized assessment	Bennett contended Hurley’s assessment was inadequate and relied on speculation.	Hurley pointed to objective evidence (two allergic reactions) and specific analysis of risk, probability, and mitigation feasibility.	Court: Hurley performed a sufficient individualized assessment under 28 C.F.R. § 35.139 and relied on actual risks, not stereotypes.
Interactive process (good faith)	Bennett argued Hurley failed to engage/identify a workable accommodation.	Hurley said it engaged, proposed counter‑accommodations (crate/breaks), and consulted medical staff.	Court: Even assuming Title II requires an interactive process, Hurley engaged in good faith and offered reasonable countermeasures; no ADA violation.

Key Cases Cited

Anderson v. City of Blue Ash, 798 F.3d 338 (6th Cir. 2015) (clarifies that exclusion must be "because of" disability to prove intentional discrimination)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (establishes burden‑shifting framework for discrimination claims)
Monette v. Elec. Data Sys. Corp., 90 F.3d 1173 (6th Cir. 1996) (discusses burden shifting and pretext analysis)
Roell v. Hamilton Cnty., 870 F.3d 471 (6th Cir. 2017) (recognizes failure‑to‑accommodate claims under Title II)
Ability Ctr. of Greater Toledo v. City of Sandusky, 385 F.3d 901 (6th Cir. 2004) (public entities must provide reasonable accommodations for disabilities)
Jakubowski v. Christ Hosp., Inc., 627 F.3d 195 (6th Cir. 2010) (offering reasonable counter‑accommodation evidences good faith)
Gohl v. Livonia Pub. Schs. Sch. Dist., 836 F.3d 672 (6th Cir. 2016) (analyzes ADA and Rehabilitation Act claims together)
Knox Cnty., Tennessee v. M.Q., 62 F.4th 978 (6th Cir. 2023) (addresses reasonable‑accommodation framework under Title II)