Conroy v. New York State Department of Correctional Services

333 F.3d 88 (2003)

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Conroy v. New York State Department of Correctional Services

United States Court of Appeals for the Second Circuit
333 F.3d 88 (2003)

  • Written by Alexander Hager-DeMyer, JD

Facts

The New York State Department of Correctional Services (correctional department) (defendant) had a sick-leave policy requiring employees to submit medical certification upon returning to work after an absence. Certifications had to include a general diagnosis informative enough to allow the corrections department to determine an employee’s eligibility for leave or the need for a return-to-work examination. Supervisors were given discretion to require certification for any length of absence, especially if the employee was suspected of attendance abuse. Correctional department employees (plaintiffs) filed suit in federal court against their employer, claiming that the general-diagnosis requirement in the sick-leave policy violated the Americans with Disabilities Act (ADA). The employees sought declaratory relief and an injunction barring the correctional department from requiring employees to submit general diagnoses. The district court granted summary judgment for the employees, finding that the certification requirement was an inquiry under the ADA and did not fall within the business-necessity exception. The correctional department appealed to the Second Circuit.

Rule of Law

Issue

Holding and Reasoning (Pooler, J.)

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