Kinney v. St. Mary’s Health, Inc.

St. Mary’s Health, Inc. (hospital) (defendant) hired Anna Kinney as its executive director of imaging services. Kinney’s job description included supervising 120 radiology employees, liaising between radiology and other hospital departments, and overseeing the installation and maintenance of equipment. In 2018, the hospital approved Kinney’s request for intermittent medical leave due to an anxiety diagnosis. In March 2020, the hospital mandated that Kinney and other employees work from home because of the COVID-19 pandemic. In August 2020, hospital staff returned to in-person work with a mandate requiring face masks. Without asking permission, Kinney continued to work from home, having junior staff perform tasks and generate reports to allow her to function remotely. Staff complaints about Kinney’s absence prompted questions about her job performance. In October 2020, Kinney’s supervisor informed her that she needed to work in the hospital at least a few days each week. Kinney said that she could not wear a mask because it heightened her anxiety. She obtained a note from her physician recommending that she work entirely from home. The hospital denied that request. It also denied a follow-up request that Kinney be permitted to work in person only two days per week and mostly from her closed office to minimize mask wearing. Eventually, Kinney resigned. She sued the hospital, alleging that the hospital violated the Americans with Disabilities Act (ADA) by failing to accommodate her disability and discriminating based on her disability. The district court granted summary judgment in the hospital’s favor. Kinney appealed.