Humphrey v. Memorial Hospitals Association

Carolyn Humphrey (plaintiff) was a medical transcriptionist for Memorial Hospitals Association (association) (defendant). Humphrey exceeded the association’s standards for speed, accuracy, and productivity in her position. However, Humphrey eventually began arriving at work late or not at all. Humphrey also began engaging in obsessive rituals surrounding showering, hair brushing, and dressing. Humphrey’s process of getting ready was extremely long, and if any part of the process was disrupted or did not feel right, Humphrey felt compelled to start over from the beginning. Humphrey received multiple disciplinary warnings and was forced to begin counseling with the association’s Employee Assistance Program. After several appointments and minimal improvement, Humphrey requested to see a psychiatrist, and the association paid for an evaluation. Humphrey was diagnosed with obsessive compulsive disorder (OCD), and her doctor submitted a letter to the association stating that the disorder contributed to Humphrey’s lateness and could be treated. The letter also stated that Humphrey might need a leave of absence for additional treatment. Humphrey met with association administrators, who set up a flexible start-time arrangement for her. However, Humphrey still missed work and asked to work from home like other association transcriptionists were doing. Humphrey’s request was denied because any employee with disciplinary actions was ineligible for working at home. Humphrey’s doctor later stated that working from home might have improved Humphrey’s condition. Humphrey’s performance evaluations indicated that absent her disability-related tardiness and absenteeism, Humphrey was a model employee. However, Humphrey continued to miss work and was terminated. Humphrey filed suit against the association for violating the Americans with Disabilities Act (ADA). The district court granted summary judgment for the association, finding that the association satisfied its duty to reasonably accommodate Humphrey’s disability.