Phyllis Stallings v. Detroit Public Schools
658 F. App'x 221
6th Cir.2016Background
- Stallings, a long-time Detroit Public Schools (DPS) early childhood educator, was reassigned to teach 5th grade in Nov. 2012, aggravated a preexisting osteoarthritic knee during an incident, and took medical leave in Dec. 2012.
- Her treating physician advised she "cannot stand longer than a minute" and recommended "no classroom — sit down job only"; Stallings submitted these notes and a Request for Accommodations to DPS.
- DPS initially provided a teacher’s aide and assigned a (second-floor) classroom with elevator access, later moved her to an administrative/desk-duty position (no classroom work) through June 2013; Stallings had knee replacement in June 2013.
- DPS recalled her for the new school year in Aug. 2013; Stallings sought FMLA leave (physician initially listed four months), then DPS denied a "no-classroom" reassignment but offered a first-floor classroom with an aide; Stallings retired Sept. 10, 2013.
- Stallings applied for Social Security disability benefits on Sept. 18, 2013; an ALJ found her disabled as of June 17, 2013 and unable to perform the demands of her past work. She then sued DPS under the ADA and Michigan PWDCRA for failure to accommodate.
- The district court granted DPS summary judgment, finding Stallings was not a "qualified individual" because she had represented she could not perform classroom work; the Sixth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Stallings was a "qualified individual" under the ADA | Stallings contends she could perform her job with reasonable accommodations (e.g., four months medical leave or reassignment to prekindergarten) | DPS contends Stallings is not qualified because she and her physician represented she could not perform classroom work and she obtained SSDI finding she was disabled | Held: Not qualified — plaintiff failed to reconcile contradiction between SSDI claim/ALJ finding that she could not work and her ADA claim that she could work with accommodation |
| Effect of applying for/receiving SSDI on ADA qualification | Stallings argues SSDI is not dispositive and can be explained | DPS argues SSDI award supports that she could not perform essential functions | Held: SSDI is relevant and creates an apparent contradiction that plaintiff failed to adequately explain under Cleveland v. Policy Mgmt. Sys. Corp. |
| Whether four-month leave was a reasonable accommodation | Stallings argues a four-month FMLA/medical leave would be reasonable to allow recovery | DPS argues the proposed leave was not shown to be reasonable and plaintiff’s statements were inconsistent | Held: Four-month leave was not shown to resolve the contradiction or to be reasonable under the circumstances |
| Whether DPS failed to engage in the interactive process or provide reasonable accommodation | Stallings says DPS refused reasonable accommodations and did not engage properly | DPS asserts it offered a first-floor classroom and a teacher’s aide (reasonable alternative) and thus met its obligations | Held: DPS offered reasonable accommodation; its duty to engage further was not triggered because plaintiff failed to propose a reasonable accommodation that would permit performance |
Key Cases Cited
- Cleveland v. Policy Mgmt. Sys. Corp., 526 U.S. 795 (U.S. 1999) (plaintiff must explain apparent contradiction between SSDI claim of inability to work and ADA claim of being able to work with accommodation)
- Cehrs v. Ne. Ohio Alzheimer’s Research Ctr., 155 F.3d 775 (6th Cir. 1998) (temporary leave can be a reasonable accommodation in appropriate circumstances)
- Demyanovich v. Cadon Plating & Coatings, L.L.C., 747 F.3d 419 (6th Cir. 2014) (SSDI application/receipt is relevant but not conclusive on ADA qualification)
- EEOC v. Ford Motor Co., 782 F.3d 753 (6th Cir. 2015) (employer must reasonably accommodate a qualified individual; interactive process principles)
- Jakubowski v. Christ Hosp., Inc., 627 F.3d 195 (6th Cir. 2010) (plaintiff bears burden to propose reasonable accommodation; reassignment denied where proposal did not address key obstacle)