Schmidt v. Solis
891 F. Supp. 2d 72
D.D.C.2012Background
- Schmidt worked for the Department of Labor’s EBSA OED as a Pension Law Specialist from 1994 to 2008.
- She suffers from endometriosis and adhesive disease, with chronic pain and bowel control issues affecting work.
- In 2001 Schmidt sought a flexible work schedule as a reasonable accommodation for her medical condition.
- In March 2002 Williams granted a five-day-a-week flexiplace arrangement (home-based) with occasional in-office requirements.
- Addendums in May 2002 clarified that off-site work could occur after 8:00 PM and that hours could be shifted to maintain full-time status.
- From 2004 onward, conflicting medical documentation requests, privacy concerns, and supervisory scrutiny culminated in revocation or modification of accommodations and increased administrative pressure.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the interactive process violated | Schmidt; DOL failed in good-faith interactive process | Raps acted within policy and sought necessary medical information | Yes; DOL failed to engage in good-faith interactive process |
| Was the flexible schedule lawfully revoked | Revocation was unjustified given two-year permissive arrangement | Revocation due to missing information was proper | No; revocation violated Rehabilitation Act |
| Was the initial accommodation properly revoked in 2004 | Revocation relied on improper handling of confidential medical data | Decision grounded in need for updated medical documentation | No; revocation violated Rehabilitation Act due to handling of records |
| Was the January 2005 in-office 15-hour requirement reasonable | 15 hours in-office contradicted medical certainty about unpredictability | ADA allows some in-office requirement if reasonable | No; requirement was unreasonable per medical evidence |
| Did Schmidt establish retaliation | Actions were retaliatory for protected accommodation requests | Actions were non-retaliatory administrative decisions | Yes; retaliation established; actions motivated by vindictiveness |
Key Cases Cited
- Mogenhan v. Napolitano, 613 F.3d 1162 (D.C. Cir. 2010) (interactive process requires good-faith effort by employer)
- Aka v. Wash. Hosp. Ctr., 156 F.3d 1284 (D.C.Cir. 1998) (intent not required for failure to accommodate)
- Scarborough v. Natsios, 190 F. Supp. 2d 5 (D.D.C. 2002) (considerations for reasonable accommodation)
- Graffius v. Shinseki, 672 F. Supp. 2d 119 (D.D.C. 2009) (standards for disability discrimination and accommodation)