869 F. Supp. 2d 609
E.D. Pa.2012Background
- Mills, a secretary at Temple, suffered a work-related back injury affecting lifting and filing tasks.
- Temple allowed intermittent FMLA leave for medical appointments; Mills sought additional leave with medical certifications.
- In 2009, Mills’ physician-certified restrictions included filing and lifting limitations; Temple considered accommodation options.
- Temple ultimately placed Mills on unpaid continuous FMLA leave and terminated her for being absent without authorization after paperwork delays.
- Mills filed this suit alleging ADA discrimination (failure to accommodate and retaliation), FMLA interference, and due-process claims; Temple moved for summary judgment.
- The court grants summary judgment on the due-process claim and denies it on ADA and FMLA-related counts, finding genuine disputes of material fact.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ADA failure to accommodate | Mills was disabled and not reasonably accommodated. | Mills is not disabled or accommodation offered was reasonable. | Genuine disputes preclude summary judgment on accommodation. |
| ADA retaliation | Temple’s leave decision after Gupta's letter was retaliatory for seeking accommodation. | Proffered nonretaliatory reason for leave is legitimate. | Genuine disputes preclude summary judgment on retaliation. |
| FMLA interference | Temple interfered by requiring recertification and unpaid leave contrary to FMLA rights. | Recertification and leave fall within allowed FMLA procedures. | Genuine disputes preclude summary judgment on interference. |
| Due process | Alleges procedural due-process violation related to termination. | Temple is entitled to judgment as a matter of law. | Granted in Temple's favor; Mills waived the claim. |
Key Cases Cited
- Williams v. Phila. Hous. Auth. Police Dep’t, 380 F.3d 751 (3d Cir.2004) (ADA discrimination and reasonable accommodation standard; guidance on interactive process)
- Taylor v. Philadelphia Housing Authority Police Dept., 184 F.3d 296 (3d Cir.1999) (interactive process duties and reasonable accommodation framework)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (Supreme Court 1973) (burden-shifting framework for discrimination claims)
- Krouse v. Am. Sterilizer Co., 126 F.3d 494 (3d Cir.1997) (causation and prima facie retaliation analysis in McDonnell Douglas framework)
- Burlington Northern Santa Fe Ry. v. White, 548 U.S. 53 (U.S.2006) (adverse action standard for retaliation claims)
- Conneen v. MBNA Am. Bank, N.A., 334 F.3d 318 (3d Cir.2003) (knowledge of disability and duty to engage in interactive process)
- Sarnowski v. Air Brooke Limousine, Inc., 510 F.3d 398 (3d Cir.2007) (standards for FMLA interference claims)
- Sconfienza v. Verizon Pa., Inc., 307 Fed.Appx. 619 (3d Cir.Pa.2008) (nonprecedential; FMLA/ADA-related reasoning cited)