Hostettler v. College of Wooster, No. 17-3406 (6th Cir. 2018)Annotate this Case
Wooster hired Hostettler in 2013; she was pregnant. Wooster allowed new employees 12 weeks unpaid maternity leave under the Family and Medical Leave Act (FMLA), 29 U.S.C. 2601–2654, even if they did not otherwise qualify. Hostettler took 12 weeks of leave but as her return to work approached, she experienced severe postpartum depression. Hostettler’s OB/GYN, Dr. Seals, prescribed an antidepressant and indicated that a reduced schedule “was medically necessary” for the “foreseeable future.” Hostettler met with her supervisor, Beasley, and did not return to work as scheduled. Wooster indicated that it would accommodate a part-time schedule until June 30. Hostettler returned to work but her symptoms continue. Hostettler contends that she was able to do everything required of her position, doing some work from home, a common practice in the department. There were no complaints about her work. Beasley stated that Hostettler never failed to perform any responsibility or timely finish any assignment. June 30 passed. The parties disagree about whether Wooster insisted that she return full-time. In mid-July, Seals submitted an updated medical certification, stating that Hostettler might return full-time in September. Beasley fired Hostettler. Hostettler sued, citing the Americans with Disabilities Act, 42 U.S.C. 12101, the FMLA, and Title VII, 42 U.S.C. 2000e. The court granted Wooster summary judgment, concluding that full-time work was an essential function of the position of HR Generalist. The Sixth Circuit reversed. Genuine disputes of material fact remain; Wooster may have preferred that Hostettler be in the office 40 hours a week but an employer cannot deny a modified work schedule without showing why the employee is needed on a full-time schedule.