A registrar sued her former school district, arguing that it had failed to provide reasonable accommodations to her and discriminated against her based on her disability. The district court dismissed her case and she appealed to the Court of Appeals.
On appeal, the court first examined the facts of the case. The registrar filed a grievance during the 2013-14 school year, arguing that she was also required to perform the job duties of an attendance clerk, effectively performing two jobs while only being paid for one. She also complained about a lack of support. Her grievance did not mention her physical health. Her grievance was resolved and she continued working as a registrar.
However, in April 2015 she suffered a flareup of ulcerative colitis and took medical leave under the Family Medical Leave Act. In July of that year, the district notified her that her leave would expire on July 26 and gave her the option to provide a doctor's release to return to work. The registrar informed the district that her doctor would not release her to return to work until further tests had been performed. The district terminated her employment and the employee filed a grievance. During the course of that grievance, the district offered to return her to work in a number of different positions, but she declined to accept them.
During the course of the lawsuit, the registrar argued that she had requested a reduced workload as an accommodation under the Americans with Disabilities Act during her grievance that had been filed prior to her medical leave. The court disagreed, noting that an employee with a disability is required to inform the employer of their need for accommodations and explain that the proposed adjustment in working conditions is due to a medical condition. In this case, the registrar failed to meet that requirement. There was no evidence to support a finding that she ever notified the district of her ulcerative colitis at any time before her medical leave, during her grievance or at any other time. Rather, her first grievance was solely focused on her concerns regarding her workload and lack of support.
The Court of Appeals also concluded that the district did not violate the ADA when it terminated the registrar's employment because she was not qualified to return to work at the time of her termination. This is because her doctor would not recommend that she return to work. The court also noted that the district had offered to reinstate her to a number of alternative positions, which it considered to be "strong evidence of a good faith effort at accommodation."
The Court of Appeals upheld the decision of the district court to dismiss the lawsuit.
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