David Marquart v. Amazon.com Services, LLC

Summary

The United States District Court for the Middle District of Pennsylvania considers Amazon.com Services, LLC’s motion for summary judgment in David Marquart’s claims under the Americans with Disabilities Act and the Pennsylvania Human Relations Act. Marquart alleges that Amazon failed to reasonably accommodate his disability by adjusting his work schedule so he could continue commuting with a coworker. The court concludes that genuine disputes of material fact exist concerning Amazon’s good-faith accommodation efforts and the availability and effectiveness of proposed accommodations, and therefore denies summary judgment.

Holdings

1. Summary judgment was inappropriate because genuine disputes of material fact existed concerning Amazon's good-faith efforts to accommodate Marquart and whether he could have been reasonably accommodated.
2. A schedule modification that enables an employee with a disability-related transportation limitation to get to work and perform the job can constitute a reasonable accommodation contemplated by the ADA.
3. Amazon did not establish on the summary-judgment record that allowing Marquart to work until 5:00 a.m. would impose an undue hardship.

Questions Presented

1. Whether Amazon engaged in the good-faith interactive process required for a disability-accommodation claim under the ADA and PHRA.
2. Whether genuine disputes of material fact existed concerning whether Marquart could have been reasonably accommodated by maintaining his 6:30 p.m. to 5:00 a.m. schedule.
3. Whether Amazon established as a matter of law that the requested schedule modification was unreasonable or would impose an undue hardship.
4. Whether summary judgment was appropriate where the parties presented conflicting evidence concerning the accommodations offered, Marquart's qualifications for alternative positions, and Amazon's communications with him.

Disposition

denied