Teresa Evans v. Vanderbilt University Medical Center

Summary

The court considers Vanderbilt University Medical Center’s motion for judgment on the pleadings in Teresa Evans’s action alleging disability discrimination and retaliation under the Americans with Disabilities Act and the Tennessee Disabilities Act. The court denies the motion as to the ADA claims but grants it as to the Tennessee Disabilities Act claim because that statute does not require reasonable accommodations.

Holdings

1. The ADA claims could not be dismissed at the pleading stage because the allegations, accepted as true, plausibly supported discrimination based on the refusal to permit a schedule that accommodated the plaintiff's disability-related inability to drive safely at night.
2. The Tennessee Disabilities Act does not impose a duty on employers to provide reasonable accommodations to disabled employees; therefore, the plaintiff's TDA accommodation claim failed as a matter of law.

Questions Presented

1. Whether the pleadings stated ADA discrimination and retaliation claims where the plaintiff alleged that the employer refused a medically supported schedule accommodation allowing her to commute during daylight hours.
2. Whether the Tennessee Disabilities Act requires an employer to provide a reasonable accommodation to a disabled employee.

Disposition

other