Santiago-Rodriguez v. Sistema San Juan Capestrano (Summary)

AMERICANS WITH DISABILITIES ACT

Santiago-Rodriguez v. Sistema San Juan Capestrano, Civil No. 11-1128 (DRD) (D. P.R. Apr. 11, 2013)

The United States District Court for the District of Puerto Rico granted a hospital’s motion for summary judgment in a lawsuit filed by a former nurse under the Americans with Disabilities Act, among other things.

The nurse, who was employed by the hospital, brought suit after she claimed she was forced to resign.  The nurse was demoted from her position as supervisor after a reporting error at work. While being interviewed about this error, the nurse mentioned that she would be having surgery at the end of the year.  After the surgery, the nurse never returned to work but sent in a letter of resignation.  The nurse claimed that she was discriminated against based on disability, among other things.

The district court held that the nurse’s disability discrimination claim was insufficient to survive summary judgment, since she was never perceived as being disabled, never worked with any condition that could be seen as a disability, and that since she was demoted before the surgery, her perceived disability had nothing to do with the demotion and subsequent resignation.