Regan v. Faurecia Automotive Seating, Incorporated, 2:10-cv-10967

Background

Plaintiff Alisha Regan, diagnosed with narcolepsy, was a Prototype Seat Builder in Faurecia's JIT Shop in Troy, Michigan from May 2005 (regular hire July 31, 2006).
In 2008 Faurecia changed JIT Shop hours from 6:00 a.m.–3:00 p.m. to 7:00 a.m.–4:00 p.m.; Garrison replaced Czerwonka, and Stuart/Hurite supervised the shop during a transition.
Regan, commuting from Perry (roughly 79 miles one-way), argued the new hours would worsen her commute; she requested to keep 6:00 a.m.–3:00 p.m. hours or to leave at 3:00 p.m. after lunch.
Her doctor noted narcolepsy and recommended reducing drive time; Regan submitted a note, but Faurecia suggested FMLA or quitting; she ultimately resigned on September 29, 2008.
Faurecia moved to summary judgment; the court held Regan was not disabled under the ADA/PWDCRA and that the company did not fail to reasonably accommodate or discriminate on gender.
Final order: the court granted Faurecia's motion for summary judgment on all claims.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Regan is disabled under the ADA/PWDCRA	Regan's narcolepsy substantially limits driving and sleeping.	Narcolepsy, as allegedly controlled, does not substantially limit a major life activity.	Regan not disabled under ADA/PWDCRA
Whether Faurecia failed to provide a reasonable accommodation	Failure to permit 6:00–3:00 schedule or equivalent accommodation.	Requests would mainly affect commute; not required accommodations under ADA.	No reasonable accommodation required; summary judgment for Faurecia on ADA/PWDCRA claims
Whether Faurecia discriminated on the basis of gender	Male employees allowed to follow the requested lunch-hour/early-leave pattern; she was not.	No adverse action or differential treatment; hours change applied to all; no credible comparators show discrimination.	No prima facie case; no evidence of discrimination
Whether Regan constructionally discharged/retaliated due to accommodation denial	Change in hours constitutes constructive discharge; she was forced to quit.	Hours change did not create intolerable conditions or intent to force resignation; not a constructive discharge.	No constructive discharge; no adverse action supporting discrimination claim
Whether there are material facts precluding summary judgment on any claim	There are triable issues regarding disability and reasonable accommodation.	No genuine issues of material fact; undisputed evidence supports judgment for Faurecia.	No genuine issues; summary judgment affirmed

Key Cases Cited

Sutton v. United Air Lines, Inc., 527 U.S. 471 (1999) (individualized inquiry for disability and ameliorative measures)
Texas Dep’t of Cmty. Affairs v. Burdine, 450 U.S. 248 (1981) (burden-shifting framework for discrimination proof)
White v. Burlington Northern & Santa Fe Ry. Co., 364 F.3d 789 (6th Cir. 2004) (adverse employment action must be materially adverse; not mere inconvenience (en banc))
DiCarlo v. Potter, 358 F.3d 408 (6th Cir. 2004) (prima facie case framework for discrimination under Title VII/ELCRA)
Wexler v. White’s Fine Furniture, 317 F.3d 564 (6th Cir. 2003) (refuting discriminatory pretext under Burdine framework)
Gonzales v. Nat’l Bd. of Medical Examiners, 225 F.3d 620 (6th Cir. 2000) (substantial limitation analysis for ADA disability)