Jessica Ehlers v. University of Minnesota, No. 21-1606 (8th Cir. 2022)
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Plaintiff sued her former employer, the University of Minnesota, under the Americans with Disabilities Act (“ADA”), for discrimination based on her disability, failure to provide a reasonable accommodation for her disability, and retaliation. The district court granted summary judgment to the University.
The Eighth Circuit affirmed the district court’s ruling. The court first addressed whether Plaintiff met her burden to show that the University failed to provide a reasonable accommodation; specifically, whether Plaintiff qualified for any alternative positions. The court held that Plaintiff did not meet her burden, reasoning that she did not submit the job posting, the job title, or any evidence of the duties or requirements of any position.
Further, the court addressed whether the University failed to engage in the interactive process. The court concluded that there is no genuine dispute of material fact about whether the University acted in good faith to make reasonable accommodations for Plaintiff. The University offered to help Plaintiff find a new job many times and considered adopting technologies to help Plaintiff perform her job duties. Once the University realized Plaintiff could not be accommodated in her current position, an employee from the job center reached out to Plaintiff to schedule a meeting about vacant positions. But Plaintiff cancelled it, and the rescheduled meeting could not take place because Plaintiff went on full-time medical leave. Moreover, even if the University did not use good-faith efforts, Plaintiff needed to show that she “could have been reasonably accommodated but for the employer’s lack of good faith.”
Court Description: [Gruender, Author, with Benton and Erickson, Circuit Judges] Civil case - Employment discrimination. The district court did not err in granting defendant's motion for summary judgment on plaintiff's ADA claims as plaintiff failed to meet her burden to show defendant failed to provide a reasonable accommodation for her medical condition; plaintiff failed to show that she was qualified for any jobs based on the lack of evidence about the duties and requirements of the position and whether she could perform them in light of her extensive work restrictions; there is no genuine dispute of material fact as to whether the defendant acted in good faith to make reasonable accommodations for plaintiff and no reasonable jury could find defendant did not make good-faith efforts to make reasonable accommodations; there is no genuine issue of material fact as to whether the defendant failed to engage in the interactive process.
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