Law School Case Brief
EEOC v. Crain Auto. Holdings LLC - 372 F. Supp. 3d 751 (E.D. Ark. 2019)
A court should enter summary judgment if the evidence, viewed in the light most favorable to the nonmoving party, demonstrates that there is no genuine dispute as to any material fact and that the moving party is entitled to judgment as a matter of law.
Judith Vaughan began working for defendant Crain Automotive Holdings, LLC in 2016. Vaughan suffers from anxiety, depression, and panic attacks, although no one at Crain knew this prior to the events giving rise to this lawsuit. Late in the day on Monday, January 30, 2017, Vaughan began experiencing chest pains and went to the emergency room, fearing she was having a heart attack. After two days of treatment Vaughan learned her chest pain had been the result of a panic attack. She ultimately reported back to work on Friday, but she began experiencing a panic attack and left work, after emailing her supervisor. When Vaughan returned to work the following Tuesday, she met with two supervisors and was terminated. According to Vaughan, she was told at this meeting that "it was not working out" due to her health problems and that she needed to take care of herself.
Plaintiff Equal Employment Opportunity Commission (EEOC) brought this action asserting that Crain violated the Americans with Disabilities Act, as amended by the Americans with Disabilities Act Amendments Act of 2008. The complaint alleges that Crain failed to provide a reasonable accommodation for Vaughan and that it discharged her because of her disabilities. Crain has moved for summary judgment on both of the EEOC's claims.
Crain moves for summary judgment on the EEOC's first claim: that Crain failed to accommodate Vaughan. Under the ADA, discrimination includes "not making reasonable accommodations to the known physical or mental limitations of an otherwise qualified individual with a disability."
Crain argues that the failure to accommodate claim fails because the discriminatory firing claim fails. Crain next argues that it had no knowledge of Vaughan's disabilities, but as explained above, a jury could find that Crain was aware of Vaughan's disabilities. Finally, Crain argues that Vaughan never requested an accommodation as a disabled individual must do in a failure to accommodate case.
Should the court grant defendant employer's motion for summary judgment in an EEOC action asserting that the employer violated the Americans with Disabilities Act by failing to provide a reasonable accommodation for an employee and by discharging the employee because of her disabilities?
The United States District Court denied defendant Crain's motion for summary judgment on both of plaintiff EEOC's claims. Here, Vaughan says that she emailed a doctor's note to Lynch, and that the doctor's note stated that she needed three weeks off work. Vaughan has produced the email in which she stated that a letter from her doctor was attached, and in which an attached note is visible, but unclear. Document #30-11. Lynch says she received the email but no doctor's note was attached to it. The Court must assume at this stage that Lynch received the doctor's letter. Given this fact, and given that Crain did not follow up whatsoever on what was contained in Vaughan's doctor's letter before firing her, the EEOC has generated a genuine dispute of fact on whether Vaughan requested an accommodation. Because it is undisputed that Crain did not accommodate Vaughan, the failure to accommodate claim goes forward.
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