Crowe v. Appalachian Stitching Company, LLC
Annotate this CasePlaintiff Patricia Crowe appealed a Superior Court order granting summary judgment to defendant Appalachian Stitching Company, LLC (Appalachian), on Crowe’s claim that Appalachian violated the Americans with Disabilities Act (ADA) and RSA chapter 354-A by refusing to accommodate her sciatica. Crowe worked at Appalachian as an assembler, which required her to have the ability to bend, lift and turn freely. After a trip to the emergency room, Crowe returned to work and informed her supervisor she had been diagnosed with sciatica. Crowe requested the ability to sit until her pain subsided and she could resume standing. Appalachian requested a doctor’s note explaining her condition; she obliged with the emergency room discharge instructions that stated, “NO LIFTING, BENDING OR STOOPING FOR 1 WEEK.” After reviewing the discharge instructions, Appalachian sent Crowe home until she was released to work by her doctor. On June 1, 2017, after Crowe missed work for eight days without providing an update on her condition, Appalachian determined that she had voluntarily quit. The trial court granted summary judgment to Appalachian on the ground that Crowe had not established she was a “qualified individual” under the ADA or RSA chapter 354-A. On appeal, Crowe argued that she could have performed the essential functions of her job if Appalachian had not sent her home and, instead, continued to allow her to sit as requested. The New Hampshire Supreme Court found that an employer, did not need to provide futile or ineffective accommodations. "Once Crowe was on leave, Appalachian was entitled to rely on the doctor’s evaluation that Crowe was unable to return to work. ... although a request for leave can, in some circumstances, trigger an employer’s obligation to make reasonable accommodations under the ADA, Crowe’s doctor’s inquiry about the availability of FMLA was not such a request." Accordingly, the Supreme Court concluded the trial court correctly determined that Appalachian was entitled to summary judgment on Crowe’s ADA and RSA chapter 354-A claims.
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