Wheeler v. Jackson National Life Insurance Co.
666 F. App'x 453
| 6th Cir. | 2016Background
- Wheeler worked as a Floating Internal Wholesaler at Jackson, a position created as an accommodation; primary duty was to log into an in-office telephone queue to answer calls.
- Wheeler suffers from narcolepsy, bipolar disorder, anxiety, and related conditions; Jackson previously granted FMLA and other leaves.
- Between April 24 and July 12, 2013, Wheeler failed to badge in or log into the phone system on 34 of 58 workdays; supervisors found job duties not being met.
- HR reconciled some absences to prior FMLA hours and required Wheeler to apply for a general leave so Jackson could assess his ability to perform essential functions with or without accommodations.
- Medical certifications indicated unpredictable, possibly lifelong need for frequent leave (up to multiple days every other week and weekly absences).
- Jackson concluded leave would not enable Wheeler to return in a predictable time, terminated him August 9, 2013, and the district court granted summary judgment for Jackson on all claims; the Sixth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| FMLA interference — whether Jackson unlawfully denied or terminated FMLA-protected leave | Wheeler contends he had remaining FMLA leave and worked remotely on many absence days | Jackson argues Wheeler exhausted FMLA and was not performing essential duties while offsite; no evidence of approved remote work or actual work performed | Court held no FMLA interference; summary judgment for Jackson (no evidence he worked or had remote-work approval) |
| ADA discrimination/retaliation — whether termination was due to disability or retaliation | Wheeler claims termination was pretextual and motivated by disability discrimination/retaliation | Jackson asserts termination was based on inability to perform essential job functions and unpredictability of future leave needs | Court held insufficient evidence of discriminatory/retaliatory intent; summary judgment for Jackson |
| Reasonable accommodation — whether general leave was a required accommodation or termination was improper | Wheeler argues he could perform essential functions (or work remotely) and that firing instead of providing leave was improper | Jackson contends prolonged, unpredictable leave was not a reasonable accommodation and would not restore his ability to perform essential functions | Court held Jackson reasonably determined leave was not appropriate and termination was justified; no genuine fact issue |
| Evidentiary/pretext showing — whether Wheeler produced evidence creating a triable issue | Wheeler points to alleged managerial approval of remote work and his subjective assertions of working from home | Jackson emphasizes absence of corroborating evidence: no emails, no witness testimony, no proof of work product or specific approvals | Court held Wheeler failed to produce evidence to create a genuine dispute; summary judgment for Jackson |
Key Cases Cited
- Wheeler v. Jackson Nat’l Life Ins. Co., 159 F. Supp. 3d 828 (M.D. Tenn. 2016) (district court opinion granting summary judgment to defendant and articulating legal analysis on FMLA and ADA claims)