Quinones v. Univ. of Puerto Rico (Summary)

AMERICANS WITH DISABILITIES ACT

Quinones v. Univ. of Puerto Rico, Civil No. 14-1331 (JAG) (D. P.R. Feb. 13, 2015)

The U.S. District Court for the District of Puerto Rico granted in part and reversed in part a medical school’s motion to dismiss claims brought by a resident who was terminated from its residency program due to her addiction to and illegal use of prescription drugs.

The resident was released from an alcohol rehabilitation program shortly before her enrollment in the residency program. However, after enrollment, the resident began abusing the prescription drugs Soma, Ambien, and Adderall which caused her to have problems complying with the program’s requirements. The resident met with the program committee several times to discuss her addiction and performance, and after being terminated from the program, she was granted a hearing, after which her request for permanent reinstatement was rejected. The resident then filed complaints of retaliation and disability discrimination under the Americans with Disabilities Act (“ADA”) and the Federal Rehabilitation Act (“Rehabilitation Act”).

The court held that the resident did not qualify as disabled under the ADA because she was currently engaged in the illegal use of drugs. Although the ADA offers protection for those who are in recovery for a significant period of time, the court determined that being drug-free for three months is not enough time to be classified as a rehabilitated drug user. The court also stated that the resident could not be disabled under the ADA because she was still using the drugs illegally at the time of her termination. Further, the court held that, even if the resident were to qualify as a disabled individual, she still would not meet the requirements for protection under the ADA because her drug use would have rendered her unqualified to perform the functions of her job as a resident. Finally, the court held that since the resident failed to qualify under the ADA, her claim under the Rehabilitation Act also failed.

On the retaliation claim, the court found that the resident had alleged sufficient facts to support the claim that the medical school retaliated against her by denying her reinstatement into the program and permanently terminating her. The court found the proximity between her conduct and the adverse employment action to be “sufficient to establish a causal link at this preliminary stage.”