Equal Employment Opportunity Commission v. Ford Motor Co.

Jane Harris worked for Ford Motor Company (Ford) (defendant) as a resale buyer. Resale buyers served as the intermediary between steel and parts suppliers. The role required a high level of interactivity and teamwork. Resale buyers interacted with their colleagues mostly face to face and sometimes by email and telephone. Resale buyers were assigned to work in the same building as parts manufacturers known as stampers, so they could meet on a moment’s notice. Harris suffered from irritable bowel syndrome, which negatively affected her work performance and ability to be physically present at work. Harris and Ford worked out an alternative work schedule that permitted Harris to telecommute on an ad hoc basis. Ford’s policy limited resale buyers to telecommuting on one set day per week. Harris sought an accommodation of up to four days of telecommuting per week. Ford determined such an arrangement was unreasonable based on the need for face-to-face contact and Harris’s poor time management skills. In addition, four of Harris’s 10 primary duties could not be performed from home. Ford offered alternative accommodations of moving her workstation closer to the restroom or looking for a position for Harris that would be better suited to telecommuting, which Harris turned down. Harris was eventually terminated. Harris filed a charge with the Equal Employment Opportunity Commission (EEOC) (plaintiff). The EEOC sued Ford on Harris’s behalf for failure to reasonably accommodate her disability. The district court granted summary judgment in favor of Ford. A panel of the appellate court reversed, and the court took the case en banc.