Molina v. Pocono Med. Ctr. (Summary)

ADA

Molina v. Pocono Med. Ctr., No. 3:11-2276 (M.D. Pa. Aug. 26, 2013)

The United States District Court for the Middle District of Pennsylvania denied a medical center’s motion for summary judgment, concluding that there were unresolved factual issues concerning an employed nurse’s claims under the Americans with Disabilities Act (“ADA”).

The nurse was diagnosed with an autoimmune deficiency which caused her to frequently fall ill, including contracting pneumonia 16 times in a three-year period.  Because of this, the nurse took either vacation or medical leave a number of times throughout her employment.  During a period of Family Medical Leave Act leave after the nurse contracted MRSA pneumonia, the nurse’s treating physician wrote a note that she could return to work with certain accommodations, such as not being exposed to infected patients.  The nurse’s immediate supervisor refused to allow her to return to work as a nurse.  The nurse sued, claiming violations of the ADA and the Pennsylvania Human Relations Act.

The medical center filed a motion for summary judgment, arguing that the nurse was precluded from pursuing claims because in her application for Social Security Disability Insurance (“SSDI”), she indicated that she was “unable to work.”  The medical center also argued that it had a legitimate non-discriminatory reason for not allowing the nurse to return to work.  The court disagreed, holding that the nurse’s SSDI claim did not preclude her ADA claim because the SSDI claim, as opposed to the ADA claim, did not take into account the possibility of a reasonable accommodation.

Further, the medical center’s unsupported assertions that it “clearly was not safe for [the nurse] to return to work” did not qualify as a legitimate non-discriminatory reason for its action in the face of the nurse’s “ample evidence that she can perform the essential functions of her job with reasonable accommodations.”