Pena v. Honeywell International

Mayra Pena (plaintiff) worked as a machine operator for Honeywell International, Inc. (Honeywell) (defendant). Honeywell cross-trained all of its employees to work in multiple areas of the manufacturing plant, including the molding department. Unlike in the other departments, the molding-department machines’ timing was not controlled by the employees. Pena told her supervisor that working in the molding department emotionally harmed her and requested to work elsewhere. Pena submitted doctors’ notes to receive accommodations, but Honeywell did not provide accommodations because the submitted notes did not contain medical diagnoses or supporting medical records. The notes stated only that Pena would be able to continue working if removed from the molding department. After Honeywell’s denial, Pena stayed home from work for three months, and once Pena’s medical leave ran out, Honeywell terminated Pena for job abandonment. Pena then applied for Social Security Disability Insurance (SSDI) benefits with the help of legal counsel. In her application, Pena submitted sworn statements that beginning three months prior to her termination, she had been unable to work due to a disabling condition. An administrative-law judge granted the application and determined that as of three months before termination, Pena had been totally disabled by somatoform disorder, a type of mental illness that manifested in physical symptoms. Pena filed suit against Honeywell, arguing that Honeywell failed to provide reasonable accommodations under the Americans with Disabilities Act (ADA). Pena was deposed before trial and was asked to explain the inconsistencies between her SSDI application and her ADA claim. Pena stated only that she was totally disabled prior to her termination. Honeywell filed for summary judgment, and the district court granted the motion. Pena appealed to the First Circuit.