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Wells v. Cincinnati Children’s Hospital Medical Center

United States District Court for the Southern District of Ohio
2012 U.S. Dist. LEXIS 19227 (S.D. Ohio February 15, 2012)


Facts

Elizabeth Wells (plaintiff), a registered nurse, worked in a critical care transplant unit at Cincinnati Children’s Hospital Medical Center (CCHMC) (defendant) from 2003–2009. Wells received consistently positive performance reviews. In 2008, Wells began having gastrointestinal problems that caused pain, vomiting, and diarrhea. Wells underwent several surgical procedures and was prescribed oxycodone and morphine at various times to alleviate related pain. In January 2009, Wells told her supervisors she was taking prescribed morphine. CCHMC policy permitted employees to take prescription medication if it did not affect job performance. In May 2009, one of Wells’s supervisors learned of several instances of bizarre behavior by Wells that raised concerns about Wells’s ability to perform her job duties. Wells was taking a prescription drug with side effects including confusion, sedation, and other neurological impairments. Wells was suspended in May 2009. CCHMC ordered Wells to undergo a psychiatric evaluation. The results were unfavorable. Wells also consulted a substance-abuse counselor and a psychologist, both of whom expressed some concerns about Wells’s possible chemical dependency and need for outpatient drug counseling. In September 2009, Wells’s doctor wrote a note saying she could return to work with no restrictions. Wells’s supervisors remained skeptical about Wells’s fitness to practice in the critical transplant unit and expressed their concerns to human resources. Wells did some temporary and part-time work before ultimately being transferred to a different unit. Wells sued CCHMC under the Americans with Disabilities Act (ADA), 42 U.S.C. § 12101 et seq., alleging unlawful disability discrimination and retaliation.

Rule of Law

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Issue

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Holding and Reasoning (Beckwith, J.)

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  • A "yes" or "no" answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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