Teru Chang v. Institute for Public-Private Partnerships, Inc., et al.

Summary

The District of Columbia Court of Appeals affirmed summary judgment for the employer in Teru Chang's claims under the District of Columbia Human Rights Act and District of Columbia Family and Medical Leave Act. The court held that Chang did not present sufficient evidence that her employer regarded her as disabled. Although the court concluded that her hypertension and resulting absence could qualify as a serious health condition and that the DCFMLA permits a retaliation claim based on taking protected leave, it held that she failed to show that the employer's stated reasons for termination were pretextual.

Holdings

1. Chang failed to present sufficient evidence that IP3 regarded her hypertension as substantially limiting her ability to work or as preventing her from performing a class or broad range of jobs. The DCHRA disability-discrimination claim therefore failed as a matter of law.
2. Chang presented sufficient evidence from which a reasonable jury could find that she had a serious health condition under the DCFMLA because she was incapacitated for more than three consecutive days, received medical treatment, was prescribed medication, and was advised to remain home.
3. The DCFMLA makes it unlawful to terminate an employee because the employee has taken protected family or medical leave.
4. Chang's allegation that she was terminated in whole or in part for exercising her right to medical leave fairly stated a DCFMLA retaliation claim, even though she did not use the word retaliation.
5. Chang failed to show that IP3's legitimate, nondiscriminatory reasons for termination were pretextual. Temporal proximity between protected leave and termination, standing alone, was insufficient under the circumstances.

Questions Presented

1. Whether Chang presented sufficient evidence that IP3 regarded her as disabled under the DCHRA.
2. Whether Chang's hypertension and treatment constituted a serious health condition protected by the DCFMLA.
3. Whether the DCFMLA permits a retaliatory-termination claim based on an employee's taking protected medical leave.
4. Whether Chang's complaint sufficiently pleaded a DCFMLA retaliation claim.
5. Whether Chang presented sufficient evidence that IP3's stated reasons for terminating her were pretextual.

Disposition

affirmed