Rosado v. Leprino Foods Company

Summary

The United States District Court for the Eastern District of California granted Leprino Foods Company’s motion for summary judgment in an employee’s claims arising from the termination of her employment after more than a year of medical leave. The court held that the requested further leave was not a reasonable accommodation because the evidence did not show that it would likely enable Rosado to return to work or that it would be the final extension. The court rejected the related FEHA discrimination, retaliation, accommodation, interactive-process, failure-to-prevent-discrimination, wrongful-termination, and California Family Rights Act retaliation claims.

Holdings

1. The requested additional leave was not a reasonable accommodation because, based on the facts known to Leprino when it made the termination decision, it was not likely that Rosado would be able to return to work after the leave and there was no indication that the extension would be the last one.
2. Rosado could not prevail on her FEHA disability-discrimination, failure-to-accommodate, interactive-process, failure-to-prevent-discrimination, or wrongful-termination claims because she could not perform her essential job duties and the only accommodation she proposed was unreasonable additional leave.
3. Rosado presented no evidence from which a reasonable jury could find that Leprino terminated her because she requested or took leave rather than because she could not perform her essential job duties and no reasonable accommodation was available.

Questions Presented

1. Whether Rosado's requested additional six-month leave was a reasonable accommodation under the California Fair Employment and Housing Act.
2. Whether the undisputed evidence established that Rosado could perform the essential functions of her job with a reasonable accommodation.
3. Whether Leprino's termination decision supported Rosado's FEHA disability-discrimination, failure-to-accommodate, interactive-process, failure-to-prevent-discrimination, wrongful-public-policy-termination, and retaliation claims.

Disposition

other