Regan v. Faurecia Automotive Seating, Inc., 679 F.3d 475

Regan, diagnosed with narcolepsy, worked as a Prototype Seat Builder for Faurecia since 2005; she disclosed her condition to Faurecia before employment.
Faurecia changed the department’s hours from 6:00 a.m.–3:00 p.m. to 7:00 a.m.–4:00 p.m. in 2008 for productivity reasons, effective September 29.
Regan commuted from Perry, Michigan (about 79 miles) and testified heavier traffic would worsen fatigue; she requested 6:00 a.m.–3:00 p.m. or 7:00 a.m.–3:00 p.m. without lunch.
Faurecia HR suggested FMLA leave or quitting; Regan did not complete FMLA paperwork and eventually resigned on September 29, citing the schedule change.
Regan provided a medical note stating a 6 a.m.–3 p.m. schedule is recommended, but managers testified they never saw the note.
The district court granted summary judgment to Faurecia on all disability and gender-discrimination claims; Regan appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Regan is disabled under the ADA and MPDCRA and whether an altered schedule is a required accommodation	Regan is disabled; request for altered schedule is a reasonable accommodation	Even if disabled, commute-related schedule is not a required accommodation	No genuine dispute; schedule alteration not a required accommodation; affirm summary judgment on disability claims
Whether Faurecia was required to accommodate Regan's commute by changing hours	Employer must accommodate known limitations, including commuting where related	Accommodation does not extend to commute; not a workplace barrier	Commute-related accommodation not required; affirmed on disability claim
Whether Regan's resignation constitutes an adverse employment action sufficient for gender discrimination	Resignation/constructive discharge due to schedule denial shows adverse action	No adverse action; schedule denial was a mere inconvenience; not constructive discharge	No adverse employment action; affirmed summary judgment on gender-discrimination claims
Whether Regan can prove a prima facie case of gender discrimination under Title VII and ELCRA	Faurecia treated men more favorably by allowing lunch-through work patterns	No adverse action and no similarly situated male treatment; insufficient evidence	Prima facie case not established; affirmed summary judgment on gender-discrimination claims

White v. Baxter Healthcare Corp., 533 F.3d 381 (6th Cir. 2008) (adverse-action standard includes significant changes in employment status)
White v. Burlington N. & Santa Fe Ry. Co., 364 F.3d 789 (6th Cir. 2004) (en banc; alteration of job responsibilities not enough for adverse action)
Kocsis v. Multi-Care Mgmt., Inc., 97 F.3d 876 (6th Cir. 1996) (definition of adverse employment action includes changes in job responsibilities)
Saroli v. Automation & Modular Components, Inc., 405 F.3d 446 (6th Cir. 2005) (constructive discharge factors and evidence considerations)
Tepper v. Potter, 505 F.3d 508 (6th Cir. 2007) (constructive discharge framework and factors for intolerable working conditions)