United States Equal Employment Opportunity Commission v. GBMC HealthCare, Inc.
1:24-cv-02803
D. MarylandApr 18, 2025Background
- 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alleging violations of the Americans with Disabilities Act (ADA) concerning Jennifer Hoffman, a deaf nurse who was rescinded a job offer after requesting accommodations.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)
