Law School Case Brief
Tyndall v. Nat'l Educ. Ctrs. - 31 F.3d 209 (4th Cir. 1994)
Under the Americans with Disabilities Act (ADA), only persons who are qualified for the job in question may state a claim for discrimination. The ADA defines "qualified individual with a disability" as an individual with a disability who, with or without reasonable accommodation, can perform the essential functions of the employment position that such individual holds or desires. 42 U.S.C.S. § 12111(8). This means that a qualified person must be able to meet all of a program's requirements in spite of his handicap. Accordingly, to determine whether a plaintiff was qualified for the position, the court must decide: (1) whether she could perform the essential functions of the job, i.e., functions that bear more than a marginal relationship to the job at issue, and; (2) if not, whether any reasonable accommodation by the employer would enable her to perform those functions. Plaintiff bears the burden of demonstrating that she could perform the essential functions of her job with reasonable accommodation.
Plaintiff Mary Tyndall suffered from lupus erythematosus, an auto-immune system disorder that caused joint pain and inflammation, fatigue, and urinary and intestinal disorders. She had been hired as a part-time instructor in the medical assisting program of the Kee Business College Campus ("Kee"), a school in Richmond, Virginia, which was owned by defendant National Education Centers ("NEC"). The head of Kee's Allied Health Department and the other Kee staff members knew of Tyndall's disability when she was hired. During Tyndall's tenure at Kee, the school made every effort to accommodate her lupus condition. In 1992, Tyndall began missing work with increasing frequency because of her lupus condition, and because she had to take care of her son who suffered from gastro-esophageal reflux disease. When Tyndall asked for more time off to accompany her son on a post-operative trip to Birmingham, Kee asked Tyndall to resign. Subsequently, Tyndall filed a complaint in federal district court against NEC, alleging violations of the Americans with Disabilities Act (ADA), 42 U.S.C.S. § 12101 et seq. The district court granted summary judgment in favor of NEC. Tyndall appealed.
Did NEC violate the ADA by discharging Tyndall, a disabled employee who was frequently absent from work due to her disability and the disability of a family member?
The court of appeals affirmed the district court's judgment, The court held that because Tyndall's attendance problems rendered her unable to fulfill essential functions of her job, and those problems occurred even with reasonable accommodations, she was not a "qualified individual with a disability" within the meaning of the ADA. Further, the undisputed evidence created a strong inference that Tyndall's termination was not motivated by bias or a desire to avoid making reasonable accommodations, and Tyndall's evidence was inadequate to establish that discrimination motivated her discharge. Tyndall’s claim under the state statute, Va. Code § 51.5-40 et seq., failed for the same reasons as her ADA claim.
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