Scruggs v. Johns Hopkins University

Summary

The United States District Court for the District of Columbia grants Johns Hopkins University’s motion for summary judgment in Yashanda Scruggs’s employment-discrimination, failure-to-accommodate, and retaliation action. The court concludes that JHU offered legitimate, nondiscriminatory reasons for terminating Scruggs based on performance and attendance, and that she failed to show pretext or retaliation. The court also concludes that Scruggs did not provide JHU notice of her mood disorder or request an accommodation for that condition.

Holdings

1. An employee's accommodation request must provide sufficient notice of the existence and nature of the disability for which accommodation is sought. Scruggs's references to her medical condition, physical and mental well-being, and stress did not notify JHU that she had a mood disorder or that such disorder impaired her ability to use public transportation.
2. Scruggs did not establish that continued 100-percent remote work was a reasonable accommodation for her position because the record showed that in-person attendance and in-person student support were essential aspects of the Director of Student Success role.
3. JHU was entitled to summary judgment on Scruggs's ADA and Title VII discrimination claims because it articulated legitimate, nondiscriminatory reasons for the termination and Scruggs failed to present evidence from which a reasonable jury could find those reasons pretextual.
4. Scruggs failed to establish a triable retaliation claim because she presented no sufficient evidence connecting her termination to her accommodation requests or her complaint against Donahue, while JHU provided unrebutted evidence of performance and attendance problems.

Questions Presented

1. Whether JHU was entitled to summary judgment on Scruggs's failure-to-accommodate claim because she did not provide sufficient notice of her alleged mood disorder, request a reasonable accommodation, or participate adequately in the interactive process.
2. Whether Scruggs presented sufficient evidence to create a genuine dispute that JHU's stated reasons for terminating her—unsatisfactory performance and attendance—were pretext for disability, race, or sex discrimination.
3. Whether Scruggs presented sufficient evidence that JHU terminated her in retaliation for requesting an accommodation or filing an internal discrimination complaint.

Disposition

other