5:23-cv-00306
E.D.N.C.Jul 18, 2025Background
- Plaintiff Christian Proffitt was employed as a Juvenile Court Counselor Trainee by NCDPS, suffering from severe menstrual pain (later diagnosed as endometriosis) and infertility issues.
- Proffitt requested accommodations including leave for fertility treatments and telework during episodes of crippling menstrual pain, disclosing some but not all details to her supervisors.
- Disputes arose over her requests and leave, with her supervisors expressing concerns about her use of sick leave and denying her request to work from home.
- Following a meeting regarding her performance and future with NCDPS, Proffitt submitted her resignation before her training period concluded.
- Proffitt filed suit alleging violations of the ADA (failure to accommodate, discrimination, retaliation, hostile work environment), FMLA (interference, retaliation), and Title VII (sex discrimination).
- Both parties moved for summary judgment; the court found factual disputes precluded summary judgment on all claims except Proffitt’s Title VII sex discrimination claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ADA: Disability/Failure to Accommodate | Proffitt’s endometriosis is an ADA-qualifying disability; NCDPS had notice and failed to accommodate. | Proffitt did not establish her condition was a disability or that the employer had adequate notice. | Proffitt’s condition can qualify as a disability, but factual dispute remains about employer notice; no summary judgment. |
| ADA: Discrimination/Retaliation | Adverse actions (denied promotion, criticism, forced resignation) were due to her disability/accommodation request. | No adverse action was taken based on disability; Proffitt was not discriminated against. | Disputed facts about adverse action and causation; summary judgment denied. |
| FMLA: Interference/Retaliation | NCDPS interfered with FMLA rights by not informing her; retaliated for exercise/attempted exercise of leave rights. | No harm from any FMLA rights interference; no adverse employment action in retaliation. | Factual disputes on whether harm/adverse action occurred; summary judgment denied. |
| Title VII: Sex Discrimination | A male employee with a disability was treated more favorably in the accommodation process. | No similarly situated comparator; not enough evidence of disparate treatment. | Proffitt failed to identify a valid comparator; NCDPS granted summary judgment on this claim. |
Key Cases Cited
- Tolan v. Cotton, 547 U.S. 650 (2014) (summary judgment standard requires inferences to favor non-movant)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (defining "material" and "genuine" disputes for summary judgment)
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (burden of proof in summary judgment)
- Fox v. Gen. Motors Corp., 247 F.3d 169 (4th Cir. 2001) (hostile work environment standard under ADA)
- Bragdon v. Abbott, 524 U.S. 624 (1998) (discussing disabilities related to reproductive system)
- EEOC v. Stowe-Pharr Mills, Inc., 216 F.3d 373 (4th Cir. 2000) (elements for ADA discrimination claims)
- Coleman v. Md. Ct. of Appeals, 626 F.3d 187 (4th Cir. 2010) (elements for prima facie Title VII discrimination)