Yasmin Reyazuddin v. Montgomery County, Maryland
789 F.3d 407
| 4th Cir. | 2015Background
- Montgomery County consolidated MC311, a large call center, using Siebel in high-interactivity mode inaccessible to blind employees.
- Reyazuddin, blind, was not transferred to MC311 and was not hired for vacancies there.
- County knew MC311’s accessibility issues since 2009 and delayed addressing them; cost estimates to implement accessibility rose over time.
- District court granted summary judgment for County on Title II claim but denied on §504 failure-to-accommodate and disparate-treatment claims.
- Evidence on whether proposed accommodations (standard-interactivity run concurrently or widget) were reasonable and whether the County’s undue-hardship defense applied was contested.
- Court reverses in part, affirming in part, and remands for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Reyazuddin can perform essential functions with a reasonable accommodation. | Accommodations (standard-interactivity mode or a CTI Toolbar widget) are feasible. | High-interactivity configuration maximizes productivity; accommodations would be undue hardship. | Genuine issues of material fact remain. |
| Whether the County provided a reasonable accommodation and whether undue hardship applies. | Proposed accommodations are reasonable and not shown to cause undue hardship. | Cost and operational impact show undue hardship. | Genuine issues of material fact; not entitlement to summary judgment. |
| Whether the non-transfer to MC311 constitutes prohibited discrimination under §504. | Failure to transfer was discriminatory on the basis of disability. | Undue-hardship/other factors justified the decision. | Issue of material fact; remand warranted. |
| Whether Title II can surveil public-employment discrimination claims against a public employer. | Title II does not cover public employment discrimination; affirmed on Title II claim. |
Key Cases Cited
- Barnett v. U.S. Airways Group, Inc., 535 U.S. 391 (2002) (undue hardship and reasonable accommodations framework; burden-shifting standard)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (framework for proving discrimination (prima facie, shift in burden, pretext))
- Halpern v. Wake Forest Univ. Health Scis., 669 F.3d 454 (4th Cir. 2012) (reasonable accommodation and undue-hardship analysis at summary judgment)
- Rogers v. Dep't of Health & Envtl. Control, 174 F.3d 431 (4th Cir. 1999) (Title II employment-related considerations referenced in prior context)
- Mary Jo C. v. N.Y. State & Local Ret. Sys., 707 F.3d 144 (2d Cir. 2013) ( Title II scope; separation of Title I/II functions)
- Elwell v. Okla. ex rel. Bd. of Regents of Univ. of Okla., 693 F.3d 1303 (10th Cir. 2012) (Title II structure and scope analysis supporting non-employment coverage)
- Brumfield v. City of Chicago, 735 F.3d 619 (7th Cir. 2013) (Title II limitations; scope of public-services discrimination)
- Zimmerman v. Or. Dep't of Justice, 170 F.3d 1169 (9th Cir. 1999) (Title II interpretation supporting separate employment considerations)
- Doe v. Univ. of Md. Med. Sys. Corp., 50 F.3d 1261 (4th Cir. 1995) (application of McDonnell Douglas framework to Title I claims)