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Humphrey v. Mem'l Hosps. Ass'n - 239 F.3d 1128 (9th Cir. 2001)


Once an employer becomes aware of the need for accommodation, that employer has a mandatory obligation under the Americans with Disabilities Act (ADA) to engage in an interactive process with the employee to identify and implement appropriate reasonable accommodations. An appropriate reasonable accommodation must be effective, in enabling the employee to perform the duties of the position. The interactive process requires communication and good-faith exploration of possible accommodations between employers and individual employees, and neither side can delay or obstruct the process. Employers, who fail to engage in the interactive process in good faith, face liability for the remedies imposed by the statute if a reasonable accommodation would have been possible.


Carolyn Humphrey worked as a medical transcriptionist. She had obsessive compulsive disorder (OCD). Humphrey requested a work-at-home position to accommodate her OCD. Her request was denied on the ground of her prior disciplinary warnings for tardiness and absenteeism. Humphrey was eventually fired. The district court granted Memorial Hospitals Association (MHA) summary judgment on the theory that MHA had satisfied its duty to reasonably accommodate Humphrey’s disability. Humphrey sought appellate review.


Did MHA violate the reasonable accommodation requirement under the Americans with Disabilities Act?




The Court of Appeals for the Ninth Circuit reversed, holding inter alia (1) there was a triable issue of fact as to whether Humphrey would have been able to perform the essential duties of her job with the accommodation of a work-at-home position; and (2) a jury could reasonably find the requisite causal link between a disability of OCD and Humphrey's absenteeism and conclude that MHA fired Humphrey because of her disability.

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