Eagle v. Hurley Med. Ctr. (Summary)

AMERICANS WITH DISABILITIES ACT

Eagle v. Hurley Med. Ctr., No. 12-13704 (E.D. Mich. June 27, 2013)

The United States District Court for the Eastern District of Michigan denied a medical center’s motion for summary judgment and motion for protective order, reasoning that issues remained whether the medical center did indeed violate the Family and Medical Leave Act (“FMLA”), Americans with Disabilities Act (“ADA”), and Michigan’s Persons with Disabilities Civil Rights Act (“PDCRA”) when it terminated a pharmacy employee for walking out on her job.  The pharmacy employee, who suffered from lupus, alleged that the medical center terminated her because she left without permission during her shift when assigned to a more physically demanding assignment.  In reference to the FMLA claim, the court held that the employee at least informed the medical center of her intention to use FMLA and if it did not believe she was taking the day off for her lupus flare-up, it had the right to ask her to re-certify for that particular day.  Under the ADA claim, the court said that an issue remained as to whether the employee requested a reasonable accommodation and whether the medical center failed to engage in good faith communication, which precluded summary judgment.  Further, the PDCRA and ADA share the same purpose and use similar definitions and analyses, thus the resolution of the ADA claim would resolve the PDCRA claim.