Deane v. Pocono Medical Center

Stacy Deane (plaintiff) worked as a registered nurse at Pocono Medical Center (PMC) (defendant). In 1991, Deane injured her wrist while lifting a patient and was unable to work for nearly a year. Deane’s doctor eventually released Deane to return to light-duty work but restricted her from lifting more than 15 to 20 pounds. PMC subsequently determined that Deane could not work in her previous position or any other available position at PMC. PMC’s Vice President of Human Resources notified Deane that Deane could not return to work because of her “handicap.” Deane sued PMC, alleging (1) that she was disabled under the Americans with Disabilities Act (ADA) because PMC regarded her as disabled based on a misperception of her limitations, (2) that PMC had failed to accommodate Deane’s lifting restrictions, and (3) that PMC had terminated Deane based on PMC’s misperception that Deane was disabled. Deane asserted that she was a qualified individual under the ADA because she could perform the essential functions of a nursing position with or without reasonable accommodations. Specifically, Deane asserted that PMC could have accommodated her lifting restriction by allowing an assistant to help her move patients or by assigning her to an area of the hospital where nurses were not required to perform heavy lifting, among other accommodations. Deane asserted in the alternative that lifting is not an essential function of nursing because lifting is only a small part of a nurse’s duties. PMC contended that lifting is an essential function of nursing and pointed to PMC’s job description, which described frequent lifting of patients as a major responsibility of PMC’s nursing staff. PMC further contended that Deane’s critical job demands included lifting laundry bags and lifting and repositioning patients. PMC also claimed that a nurse’s inability to lift patients presented safety risks for the nurse and the patients. The district court granted summary judgment in PMC’s favor, and Deane appealed to the United States Court of Appeals for the Third Circuit. After the case was decided initially by a three-judge panel, the Third Circuit reheard the case en banc.