Morrissey v. Laurel Health Care Co., No. 18-1704 (6th Cir. 2019)
Annotate this CaseMorrissey, a licensed practical nurse, worked for Coldwater, a skilled nursing and rehabilitation center, from 2001 until she quit in 2016. Morrisey alleges that she was under a 12-hour work restriction due to a disability from 2012 onward, and Coldwater forced her to work beyond that restriction, compelling her to quit. She sued under the Americans with Disabilities Act, 42 U.S.C. 12112(b)(5)(A), for discrimination, failure to accommodate, and retaliation. Morrissey provided evidence that: she was disabled; Coldwater had a blanket policy of denying all requests for accommodation if the injury was not work-related; Coldwater forced Morrissey to work beyond her medical restrictions; and Coldwater targeted Morrissey after she complained. The Sixth Circuit reversed summary judgment in favor of Coldwater, holding that Morrissey established that she has a disability and had requested an accommodation. Numerous material factual issues remain in dispute: whether Morrissey’s restriction remained in effect, whether it was Coldwater’s policy to honor only those work restrictions that were based on work-related injuries, and whether an accommodation would have caused Coldwater undue hardship.
The court issued a subsequent related opinion or order on December 23, 2019.
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