Summary
The Eighth Circuit affirmed summary judgment for the employer on ADA and Nebraska Fair Employment Practices Act failure-to-accommodate claims. The court held that while an accommodation request need not use magic words, the employee must make clear she wants assistance for her disability; here, the employee’s complaints about noise and office layout and her request to return to driving were not connected to her known back pain, so she failed to show she requested an accommodation for her alleged disability. The decision underscores that merely requesting a change in working conditions, without linking the request to a medical condition, does not trigger the employer’s duty to accommodate under the ADA.
Topics
Practice areas
Questions Presented
- Whether the district court properly granted summary judgment on Powley's failure-to-accommodate claims because there was no genuine issue of material fact that she requested a reasonable accommodation for her disability.
Holdings
- Summary judgment was proper because there was no genuine issue of material fact that Powley had not actually requested a reasonable accommodation for her alleged disability. She did not submit a doctor's note or indicate to RCX that her request to return to driving was connected to her back pain, nor did she inform RCX that headaches or migraines interfered with her work.
Key quotations
“For an ADA failure-to-accommodate disability-discrimination claim, a plaintiff 'must establish both a prima facie case of discrimination based on disability and a failure to accommodate it.'” (3)
“a plaintiff must prove, among other elements, that she 'requested accommodations or assistance for . . . her disability.'” (3-4)
Factual background
Powley worked as a driver and later dispatcher for RCX. She had a history of back pain and provided multiple doctor's notes requesting accommodations, which RCX granted. In late 2018, she requested to return to a driving position due to office noise and headaches, but did not submit a doctor's note linking her request to a disability. RCX treated her subsequent email as a resignation. Powley sued for failure to accommodate under ADA and NFEPA.
Procedural history
The district court granted summary judgment to RCX on Powley's ADA and NFEPA failure-to-accommodate and retaliation claims. Powley appealed only the dismissal of her reasonable accommodation claims.