Jessup v. Barnes Group, Inc., No. 20-1801 (4th Cir. 2022)
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In 2000, Jessup began to work for Barnes. In 2016, he suffered a panic attack and requested a leave of absence. Barnes approved that request and a subsequent extension. Jessup was prescribed medication for depression and anxiety, underwent months of therapy, started meditating, and developed relationships and activities outside of work. Jessup alleges that, upon his return to work, Barnes subjected him to discriminatory treatment and a hostile work environment; he was placed in a new position that he regarded as a demotion and Barnes raised his sales quota. Jessup suffered another panic attached and again requested leave. Barnes denied Jessup’s request, citing “significant burden to the business” and telling him to contact Human Resources if he “believe[d] some other change to [his] work environment would assist [him] in performing [his] job functions.” He did not do so. Barnes sent a letter stating it was “clear that he cannot return to work and perform the essential functions of his job, with or without accommodation.” Barnes later sent a formal termination notice.
The Fourth Circuit affirmed the summary judgment rejection of Jessup’s claims of wrongful termination, failure to accommodate, and a hostile work environment in violation of the Americans with Disabilities Act. Jessup did not establish that he was a “qualified individual.”
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