Woodruff v. LaHood
777 F. Supp. 2d 33
D.D.C.2011Background
- Plaintiff Woodruff, a FAA employee, alleged retaliation and discrimination including disability-based claims under the Rehabilitation Act.
- FAA granted Woodruff a Telecommuting Agreement and maxi-flex schedule after a 1995 shoulder/hip/back injury.
- Medical reports in 1997-1998 (Drs. McFarland/Thomas/Levitt) documented ongoing back/hip pain and guidance to limit activity and modify duties.
- Woodruff returned to work in 1998 with accommodations; FAA began reassessing his tour of duty and accommodations.
- In 1998, FAA revoked maxi-flex/telecommuting on Sept. 3, 1998 and offered leave without pay; disputes arose over adequacy of accommodations.
- Court previously granted partial summary judgment; Circuit reversed on exhaustion regarding the Rehabilitation Act claim and remanded; the current motion concerns notice, interactive process, and reasonable accommodations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Notice of disability before Sept. 1998 | Woodruff provided doctor notices (Jan/May 1998) and OWCP documents to FAA. | FAA argues insufficient awareness of non-shoulder limitations. | Genuine dispute exists as to whether FAA had notice of the disability. |
| Good-faith interactive process | Defendant did not adequately engage in the interactive process to determine a reasonable accommodation. | Defendant engaged in good-faith efforts and sought information. | Genuine dispute exists about the integrity of the interactive process. |
| Reasonableness of liberal leave without pay | Liberal leave without pay is a potentially reasonable accommodation. | Unpaid leave was not demonstrated as a reasonable accommodation. | Material fact exists on whether liberal leave was a reasonable accommodation. |
| Overall decision on summary judgment | Disputes on notice, process, and accommodation preclude summary judgment. | No triable issues; accommodation was reasonable or provider adequate. | Summary judgment denied due to material fact disputes. |
Key Cases Cited
- Taylor v. Phoenixville Sch. Dist., 184 F.3d 296 (3d Cir. 1999) (employer knowledge of disability/notice standard)
- Crandall v. Paralyzed Veterans of Am., 146 F.3d 894 (D.C. Cir. 1998) (burden on employee to provide notice of disability and request accommodation)
- Pantazes v. Jackson, 366 F. Supp. 2d 57 (D.D.C. 2005) (interactive process; employer duty to determine reasonable accommodation)
- Aka v. Washington Hosp. Ctr., 156 F.3d 1284 (D.C. Cir. 1998) (employer failure to accommodate; undue hardship standard)
- Graffius v. Shinseki, 672 F. Supp. 2d 119 (D.D.C. 2009) (prima facie case and interactive process principles under Rehabilitation Act)