Garcia-Ayala v. Lederle Parenterals, Inc.

212 F.3d 638 (2000)

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Garcia-Ayala v. Lederle Parenterals, Inc.

United States Court of Appeals for the First Circuit
212 F.3d 638 (2000)

  • Written by Arlyn Katen, JD

Facts

Zenaida Garcia-Ayala (plaintiff) was a secretary for Lederle Parenterals, Inc. (Lederle) (defendant) from 1983 until 1996. In 1986, Garcia-Ayala was diagnosed with breast cancer. In 1987 and 1993, Garcia-Ayala missed 184 days and 115 days of work, respectively, for cancer-related medical procedures, but Garcia-Ayala complied with Lederle’s short-term-disability (STD) benefits program. Lederle stopped holding a job position open for Garcia-Ayala on March 19, 1996, after Garcia-Ayala exhausted an STD leave period and started receiving long-term-disability (LTD) payments. On or around April 9, Garcia-Ayala informed Lederle that doctors predicted that she could return to work July 30 (Garcia-Ayala was ultimately cleared on August 22). Lederle denied Garcia-Ayala’s request to extend her STD leave until July 30 and instead formally terminated her on June 13. Lederle used temporary employees to fill Garcia-Ayala’s former role until February 1997. Garcia-Ayala sued Lederle in federal district court, alleging that Lederle had violated the Americans with Disabilities Act (ADA) by failing to reasonably accommodate her through allowing additional leave. Lederle filed a summary-judgment motion, primarily arguing that Garcia-Ayala was not a qualified individual under the ADA because her requested accommodation was unreasonable. Lederle did not argue or present any evidence that Garcia-Ayala’s accommodation presented an undue hardship for Lederle. The district court granted Lederle’s summary-judgment motion without considering Garcia-Ayala’s particular circumstances, and Garcia-Ayala appealed.

Rule of Law

Issue

Holding and Reasoning (Lynch, J.)

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Casebooks

Disability Law

Key Terms

  • Summary JudgmentA final ruling that there is no genuine issue of material fact in dispute and that the moving party is entitled to judgment as a matter of law. Summary judgment may also be called summary disposition.
  • Per Se RuleA rule that is applied uniformly without consideration of the specific situation or circumstance.
  • Judgment as a Matter of Law (JMOL)A judgment issued by a judge at trial on the ground that the evidence does not support a basis for the jury to decide otherwise.
  • Americans with Disabilities Act (ADA)Enacted in 1990, the law prohibits discrimination on the basis of disability under certain circumstances.
  • Reasonable AccommodationA change or modification to a system, environment, policy, procedure, or task to provide access or equal enjoyment for an individual based on a proven need. Accommodations are not reasonable if they create an undue financial or administrative burden, fundamentally alter the program or system's nature, or endanger the health and safety of others.
  • Undue HardshipA burden, obstacle, or difficulty placed on a party that is unwarranted or imposes excessive or disproportionate administrative or financial costs. An undue hardship may also be called an undue burden.

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