Whitfield v. Tennessee, 639 F.3d 253

Whitfield, blind in one eye and with cerebral palsy, worked for the DFA and was later hired by DMHDD on Sept. 4, 2007 under a six‑month probationary period.
Accommodations at DMHDD were insufficient due to workspace layout and incompatible equipment, despite prior accommodations successful at DFA.
Whitfield allegedly made spelling/grammatical errors and filing mistakes at DMHDD, with criticism from Brooks and management over performance.
She was notified Feb. 7, 2008 of termination within the probationary period, with dates extended to Feb. 27, 2008.
Whitfield exhausted administrative remedies and sued the state entities under the ADA, claiming Title I discrimination and seeking damages, reinstatement, and related relief.
District court granted summary judgment for defendants, addressing Title I and potential Title II theories; Whitfield appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Title I claims permit monetary relief against states.	Whitfield seeks monetary damages under Title I.	Garrett bars monetary relief; only prospective relief via Ex parte Young.	Yes for prospective injunctive relief against official capacity.
Whether Title II damages can be pursued in employment discrimination claims.	Whitfield asserted a Title II damages claim.	Title II damages not clearly applicable to employment; Eleventh Amendment issues.	Waived Title II damages claim; no decision on applicability to employment.
What prima facie framework governs ADA employment discrimination claims in this circuit.	Monette framework should apply; five elements.	Mahon three‑element test governs at the prima facie stage.	Adopt Monette’s five‑element test for prima facie ADA discrimination.
Whether summary judgment was proper given pretext and the claimed disability discrimination.	Defendant's explanations are pretextual due to inadequate accommodations.	Whitfield’s performance problems were real and not solely due to disability; non‑pretextual reasons exist.	Summary judgment proper; no genuine issue of material fact on pretext and causation.

Bd. of Trs. of Univ. of Ala. v. Garrett, 531 U.S. 356 (U.S. 2001) (Title I does not abrogate state sovereign immunity for monetary damages but allows prospective relief)
Ex parte Young, 209 U.S. 123 (U.S. 1908) (Exemption for official-capacity actions seeking prospective relief)
Carten v. Kent State Univ., 282 F.3d 391 (6th Cir. 2002) (Claim-by-claim Ex parte Young analysis for state officials)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (Supreme Court 1973) (McDonnell Douglas burden-shifting framework for discrimination cases)
Monette v. Electronic Data Sys. Corp., 90 F.3d 1173 (6th Cir. 1996) (Adopts five-element prima facie test for ADA discrimination)
Mahon v. Crowell, 295 F.3d 585 (6th Cir. 2002) (Three-element Mahon test inconsistently applied with McDonnell Douglas framework)
Avery Dennison Corp. v. EEOC, 104 F.3d 858 (6th Cir. 1997) (Noting the pretext standard distinction at summary judgment)
Jones v. Potter, 488 F.3d 397 (6th Cir. 2007) (Affirms need to show pretext to defeat summary judgment)
Talley v. Family Dollar Stores of Ohio, Inc., 542 F.3d 1099 (6th Cir. 2008) (Related to sole-reason standard discussions)
Hedrick v. Western Reserve Care Sys., 355 F.3d 444 (6th Cir. 2004) (Affirms sole-reason standard in Sixth Circuit (pre-Montette context))
Popovich v. Cuyahoga Cnty. Ct. of Common Pleas, 276 F.3d 808 (6th Cir. 2002 (en banc)) (En banc discussion on Title II and Eleventh Amendment)