Kinghorn v. Gen. Hosp. Corp. (Summary)

AMERICANS WITH DISABILITIES ACT

Kinghorn v. Gen. Hosp. Corp.
No. 11-12078-DPW (D. Mass. July 1, 2014)

The U.S. District Court for the District of Massachusetts granted a Hospital’s motion for summary judgment, ruling that the Hospital’s termination of an employee with Asperger’s Syndrome (“Employee”) was not a violation of the Americans with Disabilities Act (“ADA”).

The employee was hired by the Hospital to work as a Bioinformatics Specialist. The job description sought someone with strong communication skills, who could work independently with very little supervision. During orientation, the Employee became very angry and hostile toward his trainer. Only then did he present the Hospital with a letter disclosing that he had Asperger’s Syndrome, and that he would need special accommodations in the future. In light of these requests, the Hospital spent considerable time and effort fashioning an organized program with clearly written instructions. Regardless, the Employee did not follow these instructions, ignoring many of the tasks assigned to him. Additionally, the Employee made his former trainer feel very uncomfortable, attempting to shadow her on multiple occasions despite numerous requests to cease contact with her. At one time the trainer’s discomfort level was so great that she locked herself in an office to create some distance from the Employee. Soon after this incident, the Employee was terminated.

All parties agreed that Asperger’s Syndrome constituted a disability under the ADA. However, the Hospital insisted that the Employee was terminated due to his inappropriate behavior, anger and aggression, and inability to perform the essential functions of the job. The court agreed with this, finding sufficient evidence that the Employee was unable to work successfully despite numerous efforts on behalf of the Hospital. The court therefore held that no reasonable jury would find the Employee able to fulfill the essential requirements of effective communication and the ability to work collaboratively or independently. Other employees went out of their way to provide accommodations for the Employee, yet he still struggled to work well in his position. Additionally, these considerable accommodations were deemed unlikely to be feasible on a long-term basis.