Santa Maria v. Pacific Bell

James Santa Maria (plaintiff) was a longtime Pacific Bell (PacBell) (defendant) employee. In January 1995, Maria made several mistakes, resulting in placement on paid leave pending approval of a termination recommendation. Maria contacted PacBell’s employee-assistance program, complaining of stress. He was referred to Dr. Gregory Larson, who diagnosed him with major depression. PacBell psychologist Dr. Paul Hersch confirmed the diagnosis. Both doctors found Maria temporarily unable to work. When Maria resumed work in August 1995, he was placed on a 30-day improvement program and told that failure to satisfy obligations would result in termination. Larson wrote a letter to PacBell’s disability nurse, stating that the program was medically inappropriate and likely violated workplace disability laws. Although Maria knew Larson wrote a letter, he never saw it. Larson’s letter caused PacBell to extend Maria’s program until December 1, 1995. Maria failed to complete the program’s objectives, resulting in his termination on December 1, 1995. In February 1996, Maria sued PacBell for age and gender discrimination in California state court. During discovery, Maria learned the contents of Larson’s letter and that Larson recommended the extended program, not Hersch as Maria had been told. On December 19, 1996, Maria filed a disability-discrimination charge with the Equal Employment Opportunity Commission (EEOC). Maria then sued PacBell in federal court, alleging violation of the Americans with Disabilities Act (ADA) for failure to reasonably accommodate his mental disability. PacBell moved for summary judgment, arguing that Maria’s ADA claim was time-barred because the EEOC charge was filed more than 300 days after his termination. The district court denied PacBell’s motion, concluding equitable estoppel or equitable tolling prevented the limitations period’s enforcement. PacBell appealed.