Monday, February 17, 2014

8th Circuit Holds "Stressed Out" Employee's Disability Discrimination Claims Fail When Nature of Job

In a decision given just before the end of 2013, the Court of Appeals for the Eighth Circuit granted a district court's grant of summary judgment against an Family Service Worker's Family and Medical Leave Act (FMLA), Fair Labor Standards Act (FLSA), Americans with Disabilities Act (ADA) and Rehabilitation Act claims.  The decision is fairly interesting because the basis of the claim was an employee's inability to perform her job and need medical leave due to stress caused by the job.  However, and what likely 'saved' this employer, is the fact they explicitly stated "stressful environment" was a part of the job and incorporated it into the job description.

The Court upheld the district court's grant of summary judgment with respect to Hill's FMLA claim because she simply was not eligible for FMLA leave as she had not worked enough during the work year to be an eligible employee for FMLA leave.  Hill attempted to cite case law where other plaintiff's successfully showed they would have been eligible during their leave time but Hill did not show the same.

Hill's FLSA claim failed because she sued her supervisor in her individual capacity and did not adequately plead that her supervisor was responsible for paying her. 

Lastly, Hill's disability discrimination claims failed because she was not able to perform an essential function of her job:  handling stressful cases.  Although Hill attempted to argue only one particular case was causing her the inability to perform the job, the Court held that "[t]he ability of individual caseworkers to pick and choose among case assignments based on their toleration of stress could wreak havoc with management of the agency, especially considering that the Department already was short staffed during Hill's leave.  See Moritz v. Frontier Airlines, Inc., 147 F.3d 784, 787 (8th Cir. 1998)."  Furthermore, Hill's Department offered accommodations, but Hill refused them all and insisted upon removal as the sole accommodation.  The Court then reminded us that an employer need not remove essential functions of a job to accommodate an employee.

The case is Yulanda Hill v. Carolyn Walker, Case No. 13-1381 (8th Cir. Dec. 16, 2013)

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