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United States Equal Employment Opportunity Commission v. GBMC HealthCare, Inc.
1:24-cv-02803
D. Maryland
Apr 18, 2025
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Background

  • The EEOC filed suit against GBMC HealthCare, Inc. and Greater Baltimore Medical Center, Inc., alleging violations of the Americans with Disabilities Act (ADA) concerning Jennifer Hoffman, a deaf nurse who was rescinded a job offer after requesting accommodations.
  • After being offered a Registered Nurse position, Hoffman disclosed her deafness and requested specific accommodations. Her healthcare provider recommended a badge, a way to text her supervisor, access to a power source for her cochlear implant, and restrictions related to MRI room access and lifting.
  • Defendants claimed they could not accommodate Hoffman’s requests due to patient care intensity and essential job functions, including lifting and accompanying patients to MRI testing areas.
  • The EEOC’s Complaint was challenged for selective quoting and omitting facts from the provider’s documentation, particularly lifting restrictions and escorting patients to MRI.
  • Defendant filed a motion to dismiss for failure to state a claim; the EEOC moved to strike a filing containing unredacted dates of birth.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether Hoffman could perform RN job's essential functions with accommodation (ADA discrimination) Hoffman could perform essential functions with or without requested accommodations; MRI access and lifting restrictions are not essential functions. Hoffman’s MRI access and lifting restrictions prevent her from performing essential RN functions; therefore, she is not "qualified" under the ADA. Motion to dismiss denied; questions of fact remain regarding essential job functions and reasonableness of accommodations.
Whether GBMC refused to engage in the ADA-required interactive process GBMC flatly refused accommodations after request, ending the interactive process. GBMC considered and rejected accommodations as unreasonable. Denied dismissal; refusal to engage in interactive process, if true, suffices at this stage.
Whether rescinding offer after accommodation request was ADA retaliation Plaintiff suffered adverse action following a protected act (accommodation request), causally linked to request. Rescinding offer was a lawful employment decision based on qualifications, not retaliation. Motion to dismiss denied; sufficient factual allegations of causal link.
Whether to strike filings with unredacted birth dates Filings violate court rules on privacy and should be stricken. Redaction was an oversight; striking is inappropriate, a redacted version was filed. Motion to strike denied; document sealed, redacted version accepted.

Key Cases Cited

  • Ashcroft v. Iqbal, 556 U.S. 662 (pleading must state a plausible claim to survive dismissal)
  • Bell Atl. Corp. v. Twombly, 550 U.S. 544 (standards for facial plausibility in complaints)
  • Wilson v. Dollar Gen. Corp., 717 F.3d 337 (prima facie case for failure to accommodate under ADA)
  • Reynolds v. Am. Nat’l Red Cross, 701 F.3d 143 (elements of ADA retaliation claim)
Read the full case

Case Details

Case Name: United States Equal Employment Opportunity Commission v. GBMC HealthCare, Inc.
Court Name: District Court, D. Maryland
Date Published: Apr 18, 2025
Docket Number: 1:24-cv-02803
Court Abbreviation: D. Maryland