Rita Morrissey v. Laurel Health Care Co., 946 F.3d 292

Background

Rita Morrissey, an LPN at The Laurels of Coldwater from 2001–2016, claimed a physician-imposed 12-hour-per-shift restriction beginning in 2012 due to back and connective-tissue conditions.
In Feb. 2012 management allegedly announced a policy refusing accommodations unless the condition was work-related; Morrissey submitted recorded meeting audio and affidavits; Coldwater disputes the policy but internal emails suggest otherwise.
Coldwater transitioned nursing units toward 12-hour shifts in late 2015; Morrissey says she requested reassignment or casual status to avoid mandatory overtime and was denied.
On Jan. 31, 2016 Morrissey was mandated to work 13.5 hours; on Feb. 4, 2016 she was told she would be mandated to work 16 hours (she left mid-shift and resigned), and she alleges being singled out although another nurse’s turn to be mandated had arrived.
District court granted summary judgment to Coldwater on disability discrimination, failure to accommodate, constructive discharge, and retaliation; the Sixth Circuit reversed and remanded, finding genuine disputes of material fact.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Morrissey was "disabled" under the ADA	Morrissey said her back and related conditions substantially limited walking, standing, bending, lifting after long shifts and produced chronic pain and numbness	Coldwater argued insufficient medical proof, she never identified diagnoses to employer, and hour restriction alone is insufficient	Court: Under the ADA Amendments Act and broad standard, disputed factual record permits finding of disability; summary judgment improper
Failure to accommodate	Morrissey requested reassignment/casual status and argued Coldwater had a blanket rule denying non–work-related accommodations and forced her to exceed medical restriction	Coldwater denied existence of blanket policy and argued overages were de minimis or not mandated	Court: Evidence (meeting audio/emails, personnel notes, honored restriction at times, mandated 13.5 hr and attempted 16 hr) creates triable issue; failure-to-accommodate claim survives
Constructive discharge	Morrissey contends repeated refusals to honor restriction and being mandated beyond limits created intolerable conditions that forced her to quit	Coldwater said evidence was insufficient and overages were isolated/minimal	Court: Repeated denial and immediate mandate to work beyond restriction supports constructive discharge claim for jury
Retaliation	Morrissey claims protected activity (requesting accommodation/complaints) led to adverse action (constructive discharge) and causal link (being improperly mandated on Feb. 4)	Coldwater argued no adverse action and no causal link; process for mandates purportedly neutral/unclear	Court: Constructive discharge qualifies as adverse action; disputed facts on knowledge, timing, and why Morrissey was mandated preclude summary judgment

Key Cases Cited

Kleiber v. Honda of Am. Mfg., Inc., 485 F.3d 862 (6th Cir. 2007) (failure to accommodate is direct evidence of discrimination)
Talley v. Family Dollar Stores of Ohio, Inc., 542 F.3d 1099 (6th Cir. 2008) (complete refusal to accommodate can support constructive discharge)
Hostettler v. College of Wooster, 895 F.3d 844 (6th Cir. 2018) (ADA Amendments Act governs broad construction of “substantially limits”)
Monette v. Elec. Data Sys. Corp., 90 F.3d 1173 (6th Cir. 1996) (discusses direct-evidence framework for ADA claims)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden-shifting framework for indirect/circumstantial discrimination claims)
EEOC v. Dolgencorp, LLC, 899 F.3d 428 (6th Cir. 2018) (neutral policies can still be pretextual where employer refuses reasonable accommodation)
Brumley v. UPS, 909 F.3d 834 (6th Cir. 2018) (discusses failure-to-accommodate as discrimination)
Lewis v. Humboldt Acquisition Corp., 681 F.3d 312 (6th Cir. 2012) (en banc) (clarifies causation language in ADA intent analysis)