Amber Franklin sued her former employer WovenLife, Inc. claiming that WovenLife discriminated against her based on her cancer diagnosis, failed to provide reasonable accommodations to allow her continued employment, and retaliated against her for her accommodation requests under the Americans with Disabilities Act (ADA).
Statement of Undisputed Facts
Amber Franklin was employed by WovenLife, Inc., where she served in their child development program and was later promoted to assistant director. Following her cancer diagnosis, Franklin requested accommodations to address the effect of her health on her job performance, including the ability to work from home after chemotherapy treatments. WovenLife contended that it tried to accommodate Franklin’s needs but ultimately terminated her employment due to the elimination of her position and her refusal to engage in discussions about transitioning to a new role. The dispute centers on the handling of Franklin’s accommodation requests and the reasons for her termination.
Legal Analysis
Retaliation and Discrimination Claims: The court applied the McDonnell Douglas burden-shifting framework to assess Franklin’s retaliation and discrimination claims. WovenLife argued that it had legitimate, nondiscriminatory reasons for Franklin’s termination, related to the closure of the Hope Center and the elimination of her assistant director position. The court found that WovenLife provided a legitimate reason for Franklin’s termination and that Franklin failed to show these reasons were pretextual. Consequently, WovenLife was granted summary judgment on the retaliation and discrimination claims.
Failure to Accommodate Claim: Regarding Franklin’s failure-to-accommodate claim, the court distinguished between the different accommodations requested. The court found that WovenLife did not refuse Franklin’s request to work from home and noted that there was no evidence to suggest that allowing Franklin additional time to accept a new position would have constituted a reasonable accommodation. But the court concluded that WovenLife failed to conclusively rebut Franklin’s claim about the request for a recliner, leaving this specific accommodation request for trial.
WovenLife’s motion for summary judgment was granted in part and denied in part, with Franklin’s claim about the recliner proceeding to trial.
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