Employer Reasonably Accommodated Employee's Problems Concentrating And Staying Awake
Catherine A. Mobley worked for Allstate Insurance for sixteen years before being laid off with 31 other employees in October 2003 as part of a reduction in force (“RIF”). In July 2001, Mobley had begun having problems concentrating and staying awake at work, due to what was ultimately diagnosed as essential tremor and nocturnal myoclonus. From fall 2002 until April 2003, Mobley wrangled with her supervisors over workplace accommodations for her conditions. In May 2003, Allstate permitted Mobley to regularly work in a private room rather than a cubicle. Although Mobley's earlier, temporary placement in this private room had improved her work performance, Mobley's performance level never reached the “meets” level after May 2003, causing her name to be included on the RIF in October of that year.
Mobley subsequently brought suit against Allstate under the Americans with Disabilities Act (“ADA”), bringing claims for failure to accommodate her disability, discriminatory termination, and unlawful retaliation. The district court granted summary judgment in favor of Allstate on all claims. On appeal, the 7th Circuit affirmed, holding that: (1) Allstate met its obligation to reasonably accommodate Mobley’s disability; Mobley failed to meet her burden of showing her other requested accommodations such as working from home, and switching to four ten-hour days, would not impose an undue hardship on Allstate; (2) Mobley failed to establish a prima facie case of discriminatory termination, as she was not meeting Allstate's expectations at the time she was terminated; and (3) Mobley failed to establish a prima facie case of retaliation, absent showing a causal connection between her request for reasonable accommodation and her termination.
Mobley v. Allstate Ins. Co.
The 7th Circuit Court of Appeals’ jurisdiction includes Illinois, Indiana and Wisconsin.