Tenita Webb-Eaton v. Wayne County Community College District
328069
Mich. Ct. App.Feb 21, 2017Background
- Plaintiff (Tenita Webb-Eaton) was admitted to Wayne County Community College District (WCCCD) nursing program but has a latex allergy and could not complete required clinical rotations at local hospitals.
- WCCCD and hospital partners provided some latex-reduction measures (latex-free areas, non‑latex supplies) but could not guarantee complete removal of latex from clinical sites.
- Plaintiff sued under the Persons with Disabilities Civil Rights Act (PWDCRA), claiming the allergy was an unrelated disability and that reasonable accommodations could enable her to complete the program.
- The trial court granted summary disposition for defendants; the Court of Appeals majority affirmed dismissal.
- Judge Kelly concurred separately, arguing plaintiff’s latex allergy is related to her ability to utilize and benefit from the educational program because completion requires clinical rotations where defendants cannot eliminate latex.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether plaintiff has a "disability" under PWDCRA for educational benefits | Allergy is unrelated to ability to use/benefit from program because accommodations could allow completion | Allergy is related because core requirement (hospital clinicals) cannot be made completely latex-free by defendants | Allergy is related to ability to utilize/benefit; no disability under PWDCRA |
| Whether defendants must provide accommodations that eliminate all latex exposure | WCCCD must accommodate (remove or secure latex-free placements) so plaintiff can complete program | Defendants cannot control latex presence at external hospitals; complete elimination is impossible | Cannot require impossible accommodation; inability to remove all latex defeats claim |
| Standard for determining "unrelated" disability after Rourk | Plaintiff: "with or without accommodation" lowers threshold so accommodation could make allergy unrelated | Defendants: even with Rourk, accommodation cannot change the essential barriers posed by clinical rotations | Rourk allows accommodations but does not obligate impossible measures; relation depends on whether accommodation can be provided |
| Role of equitable considerations (college accepted plaintiff knowing allergy) | Equity supports allowing claim to proceed despite practical barriers | Statutory text controls; equity cannot override statutory definition of disability | Equity cannot alter statutory requirement that disability be unrelated to ability to benefit from program |
Key Cases Cited
- Rourk v. Oakwood Hosp. Corp., 458 Mich 25 (Mich. 1998) (interprets "with or without accommodation" lowering handicap proof threshold but limiting accommodation types)
- Fonseca v. Mich. State Univ., 214 Mich App 28 (Mich. Ct. App. 1995) (educational provisions of PWDCRA interpreted using employment-discrimination precedents)
- Pederv. Detroit, 470 Mich 195 (Mich. 2004) (court may dismiss statutory claims when elements, including disability, are not met)
- Miller v. Detroit, 185 Mich App 789 (Mich. Ct. App. 1990) (wheelchair users’ disability related to ability to use bus service where disability prevented bus use)
- Crancer v. Bd. of Regents of Univ. of Mich., 156 Mich App 790 (Mich. Ct. App. 1986) (outlines elements for establishing a PWDCRA educational claim)