Harris v. Reston Hosp. Ctr. (Summary)
DISABILITY DISCRIMINATION
Harris v. Reston Hosp. Ctr., No. 12-1544 (4th Cir. Apr. 24, 2013)
The United States Court of Appeals for the Fourth Circuit affirmed summary judgment in favor of a hospital after finding that a nurse who filed a lawsuit under the Americans with Disabilities Act was not a “qualified individual.”
The nurse, who had a history of impairment, tripped on the steps while walking into her house, suffered a head injury, and was hospitalized. During her hospitalization, she received a call from her supervisor asking why she was a “no call/no show” for two days. The nurse was suspended for failing to report to work, in accordance with hospital policy. After the nurse served her suspension, she reported back to work but, after clocking in, began to experience disorientation and nausea and felt that she was going to lose consciousness. The nurse met with her supervisors, who determined that since the nurse was unable to perform her job safely, termination was warranted. The nurse filed suit, and the district court granted the hospital’s motion for summary judgment, which the nurse appealed.
The appeals court found that the nurse was not within the ADA’s protected class since she was not a qualified individual with a disability. The appeals court noted that an essential function of the nurse’s job was the care and treatment of patients and found that she failed to demonstrate that she could perform this essential function since her employment record showed repeated absences and barely satisfactory-level performance evaluations.