Jacobs v. N.C. Administrative Office of the Courts - Fourth Circuit Court of Appeals
Facts: Christina Jacobs ("Jacobs") worked at a North Carolina courthouse and was soon promoted to be one of thirty deputy clerks assigned to assist customers at the front counter. However, Jacobs suffered from social anxiety disorder and other related mental illnesses. After training began, Jacobs experienced extreme stress, nervousness, and panic attacks. When Jacobs approached her supervisor with concerns, the supervisor advised Jacobs to seek treatment from her physician, which she did.
Four months later, Jacobs sent her supervisors an e-mail, disclosed her disability again and requested an accommodation. Jacobs was told she would have to wait for a different supervisor to return from a three week vacation before the problem could be addressed. Apparently, the vacationing supervisor only received one call while on vacation. An assistant called to report that Jacobs was spotted sleeping at her desk. When the supervisor returned from vacation, Jacobs was terminated.
Jacobs subsequently sued and alleged, among other things, disability discrimination, failure to accommodate, and retaliation under the Americans with Disabilities Act ("ADA"). The District Court granted summary judgment in favor of the Clerk's Office.
Holding: The Fourth Circuit Court of Appeals reversed the District Court and held that a jury could conclude both that Jacobs was disabled (within the meaning of the ADA) and that Jacob's disability was the cause of her discharge because her supervisor knew of her accommodation request prior to the termination.
In particular, the Court noted that the other twenty five or so clerks performed work that did not require interaction with the public at the front counter. As a result, there was a factual dispute whether working the front counter was actually an essential function of Jacob's position. Consequently, Jacob's request to work the counter less frequently was a reasonable accommodation that could have been made (or at least raised a triable fact issue to put before a jury).
As for any arguments by the Clerk's Office that Jacobs was terminated for legitimate nondiscriminatory reasons, the Court of Appeals did not buy that argument. The Clerk's Office had little to no documentation of Jacob's alleged poor performance, beyond witnesses to testified that Jacob's had performance issues and was a poor employee long before she was assigned to the front counter.
Judgment: The Fourth Circuit Court of Appeals reversed the District Court's granting of summary judgment in favor of the Clerk's Office and held that there are triable issues of fact that Jacobs should present to a jury on her ADA disability discrimination, retaliation, and failure to accommodate claims.
The Takeaway: As others have noted, this case is paramount if for no other reason than to remind employers to never assume that an employee's medical condition does not qualify as a disability. While the Court did not directly pinpoint social anxiety as a disability under the ADA, there was certainly enough reasoning and logic to allow this question to be put before a jury.
As well, in this instance, the employer made a detrimental mistake of not taking adequate steps to accommodate an employee who asked for an accommodation. (In fact, little if anything was done to accommodate the employee before she was fired). Had (any) steps been taken to accommodate the employee and the alleged disability, after the accommodation request had been made, the employer would have been in a more favorable position before steps were taken to terminate the employee.
Majority Opinion Judge: Judge Floyd
Date: March 12, 2015
Opinion: www.ca4.uscourts.gov/Opinions/Published/132212.P.pdf
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