Garcia-Ayala v. Lederle Parenterals, Inc.

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.