Williams v. AT&T Mobility Services, LLC
2:15-cv-02150
W.D. Tenn.Jun 6, 2016Background
- Kirsten Williams, a former AT&T call-center customer service representative, was terminated July 3, 2014 after accumulating attendance points and failing to return to work as directed.
- Williams has diagnosed depression and anxiety; she sought STD, FMLA (was ineligible for some periods), and an ADA accommodation consisting of extended unpaid leave, a flexible start time (up to one hour late), and extra unscheduled breaks for panic attacks.
- AT&T’s Attendance Guidelines track unscheduled time via an 8-point rolling 12‑month threshold; exceeding 8 points can result in termination.
- IDSC (a third‑party administrator) reviewed Williams’s medical submissions, approved some STD leave but denied other periods for insufficient documentation; Williams repeatedly communicated with IDSC.
- By June 11, 2014 Williams had 26 attendance points; management sought termination approval for excessive absenteeism and job abandonment; she did not return by set deadlines and was fired.
- The Court previously ruled Williams met the ADA disability definition; the instant decision resolves AT&T’s motion for summary judgment on accommodation, interactive‑process, retaliation, and discrimination claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the proposed flexible schedule (late start, extra breaks, extended leave) was a reasonable accommodation under the ADA | Williams: schedule flexibility and additional leave would enable her to perform job | AT&T: proposal would eliminate essential functions (regular, predictable, on‑site attendance); unreasonable because it shifts duties/coverage to others or requires indefinite leave | Court: Not reasonable as a matter of law — it would remove essential attendance function and is per se unreasonable |
| Whether regular attendance/punctuality are essential functions and whether Williams was a "qualified individual" | Williams: she could perform duties with accommodation; IDSC could manage coverage | AT&T: attendance is essential to call‑center interactive work; excessive absenteeism rendered her unqualified | Court: Attendance is an essential function; excessive, unpredictable absences made Williams unqualified under the ADA |
| Whether AT&T failed to engage in the interactive process in good faith | Williams: AT&T/IDSC didn’t meaningfully accommodate or discuss alternatives after denials | AT&T: engaged with Williams and IDSC extensively; denials were based on insufficient medical documentation | Held: Even assuming some process defects, failure to engage is not actionable because Williams cannot show a reasonable accommodation would have enabled her to perform essential functions |
| Whether termination was discriminatory/retaliatory (for requesting accommodation) | Williams: temporal proximity and denial of flexibility show termination was motivated by disability/requests | AT&T: terminated for legitimate, nondiscriminatory reasons — policy violation (excessive points) and job abandonment; requests were months earlier and attendance warnings predated termination | Court: No causal/pretext evidence; AT&T offered legitimate reasons and Williams failed to show pretext or sufficient causal link; summary judgment for AT&T granted |
Key Cases Cited
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (court must draw inferences in favor of nonmovant at summary judgment)
- Celotex Corp. v. Catrett, 477 U.S. 317 (nonmovant must present specific facts showing genuine issue for trial)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard; no weighing credibility)
- Gantt v. Wilson Sporting Goods Co., 143 F.3d 1042 (employee unable to meet attendance requirements is not a "qualified individual" under ADA)
- Brenneman v. MedCentral Health Sys., 366 F.3d 412 (attendance can be an essential function; excessive absenteeism can render employee unqualified)
- EEOC v. Ford Motor Co., 782 F.3d 753 (regular, predictable on‑site attendance is an essential function; removing it is per se unreasonable)
- Hoskins v. Oakland County Sheriff's Dep't, 227 F.3d 719 (definition and limits of essential functions under ADA)