Hostettler v. College of Wooster

Heidi Hostettler (plaintiff) worked for the College of Wooster’s (Wooster) (defendant) human-resources department. She took a leave of absence under the Family and Medical Leave Act (FMLA) when she gave birth. Hostettler experienced severe postpartum depression and separation anxiety. When the 12 weeks of FMLA-provided leave expired, Hostettler was not yet able to return to work due to her condition. Her doctor prescribed her an antidepressant. He also advised her to return to work on a part-time basis because it was medically necessary for her to work a reduced schedule. He provided a medical certification to that effect, which Hostettler submitted to her supervisor. Pursuant to the medical certification, Hostettler made arrangements with her supervisor, Marcia Beasley, regarding a part-time schedule that were amenable to both parties. Hostettler believed she had been fulfilling the duties of her job adequately despite her part-time schedule. She also completed work from home in the evenings. A fellow coworker also believed Hostettler was able to fulfill many of her duties from home. Eventually, Beasley insisted Hostettler return to work full-time. Hostettler was not quite ready for a return to full-time. After several meetings between Beasley and Hostettler, Hostettler submitted a second medical certification indicating she was still not yet ready to return to full-time work. Beasley fired Hostettler the next day, indicating that she was not qualified for her position in human resources because she was unable to work full-time. Hostettler sued Wooster for violations of the Americans with Disabilities Act (ADA), FMLA, and several other statutes. Wooster moved for summary judgment on all claims. The district court granted summary judgment in favor of Wooster, finding that full-time work was an essential job function, so Hostettler was not a qualified individual under the ADA. Hostettler appealed to the United States Court of Appeals for the Sixth Circuit.