Blanchet v. Charter Communications, LLC, No. 21-5073 (6th Cir. 2022)Annotate this Case
Blanchet sold Charter’s services door-to-door. Blanchet received Charter’s standard maternity leave, short-term disability benefits, and Family and Medical Leave Act (FMLA) benefits until September 2016, but, suffering from postpartum depression, requested additional leave. Blanchet exhausted FMLA leave, exhausted short-term disability leave, then had long-term disability leave through February 1, 2017, as an Americans with Disabilities Act (ADA), 42 U.S.C. 12112(a), accommodation. Sedgwick, a third-party administrator, was responsible for all communications with employees who requested leave and customarily delayed paperwork long after initial verbal approvals. In February 2017, Sedgwick received a letter from Blanchet’s doctor, indicating that Blanchet was not capable of working. Blanchet requested accommodation through April 3. Sedgwick representatives reassured Blanchet that her application would be approved. On March 9, Blanchet received a termination letter “effective January 10, 2017.” She received an approval letter for extended leave 10 days later. The next day, Charter’s HR officer notified Sedgwick that the extension was approved.
The Sixth Circuit reversed the dismissal of Blanchet's ADA suit. Genuine issues of material fact remain regarding Blanchet’s disability discrimination claim. A reasonable juror could find that Blanchet would be otherwise qualified for her job after her medical leave accommodation and that Blanchet’s proposed accommodation was reasonable, given that Charter considered it reasonable. Charter did not "engage" with Blanchet concerning her accommodation request.