Sánchez-Rodríguez v. AT & T Mobility Puerto Rico, Inc., 673 F.3d 1

Sánchez-Rodríguez was hired by AT&T in 2000 as an Installation Technician and moved in 2001 to Retail Sales Consultant in the Caguas region, with a salary and commissions schedule through 2006.
In Sept. 2006 Sánchez disclosed his Seventh Day Adventist faith and requested Saturdays off as a religious accommodation; AT&T acknowledged his Sabbath observance with church letters in Oct. 2006.
AT&T offered two non-Saturday positions (Rep 1 and Business Sales Specialist) that would not require Saturdays but paid less and offered no commissions; Sánchez declined due to income loss.
In early 2007 Sánchez applied for other positions but was not interviewed; he filed an EEOC charge alleging religious discrimination in Feb. 2007 with follow-up attempts about accommodations.
In Apr. 2007 AT&T described Saturday work as an essential function but proposed a two-month voluntary shift-swap pilot; Sánchez could not obtain voluntary swaps; by May 2007 he faced disciplinary status for absenteeism, and he resigned on June 20, 2007 seeking a better opportunity elsewhere.
The district court granted summary judgment for AT&T in Aug. 2010, based on a stipulation of facts and findings that the accommodations were reasonable or undue hardship; Sánchez appealed alleging denial of discovery and errors in summary judgment analysis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Rule 56(f) denial proper?	Sánchez asserts more discovery was needed	AT&T contends record adequate for summary judgment	No abuse of discretion; denial affirmed
Reasonable accommodation under Title VII?	Combination of accommodations should mitigate discrimination	Accommodations considered collectively were reasonable; undue hardship not shown	AT&T's accommodations, taken together, were reasonable; discrimination claim affirmed on this basis
Retaliation claim viability/pretext?	Disciplinary actions tied to protected activity; pretext possible	Reasons for discipline based on absenteeism; no pretext shown	Non-discriminatory reasons established; retaliation claim upheld as to pretext not shown
Case-stated basis proper?	Case-stated approach inappropriate without explicit agreement	Stipulation allowed case-stated adjudication	District court erred in case-stated approach; de novo review applied to reach judgment

Trans World Airlines, Inc. v. Hardison, 432 U.S. 63 (U.S. 1977) (reasonable accommodation may include employee-arranged shifts)
Unión Independiente de la Autoridad de Acueductos y Alcantarillados de Puerto Rico, 279 F.3d 49 (1st Cir. 2004) (prima facie burden and accommodation/undue hardship framework)
Boston Five Cents Sav. Bank v. Sec'y of Housing & Urban Dev., 768 F.2d 5 (1st Cir. 1985) (case-stated adjudication context and discovery implications)
Calero-Cerezo v. U.S. Dep't of Justice, 355 F.3d 6 (1st Cir. 2004) (causal proximity in retaliation claims)