Grenier v. Cyanamid Plastics, Inc.

Andre Grenier (plaintiff) was an electrician for Cyanamid Plastics, Inc. (Cyro) (defendant). After a workplace investigation, Grenier suffered from anxiety that prevented him from working with colleagues and led to him taking a leave of absence. Grenier’s employment automatically terminated when Grenier ran out of leave time. Grenier continued to receive disability benefits for two years after his termination. After those benefits ended, Grenier sought reemployment in the same electrician position. Cyro responded with a request for a note from Grenier’s physician certifying that Grenier could return to work without restrictions or identifying any necessary reasonable accommodations. Grenier claimed that he could perform the job but failed to provide medical documentation or to describe the necessity of any reasonable accommodations. After Cyro denied his application, Grenier sued the company for violating the Americans with Disabilities Act (ADA). The district court entered summary judgment for Cyro. Grenier appealed and argued that Cyro’s pre-offer inquiries violated the ADA. Specifically, Grenier argued that (1) the request for a medical certification was too broad in that it went beyond seeking information about his technical qualifications and (2) any request for a medical certification was prohibited at the preemployment-offer stage.