The Persons With Disabilities Civil Rights Act (PWDCRA) (MCL 37.1101 et seq.); Peden v. Detroit; MCL 37.1212(1)(a)-(e); “Disability” defined (MCL 37.1103(d)); Whether the plaintiff-corrections officer’s (CO) disability was related to her ability to perform her job; MCL 37.1212(1)(l)(i); MCL 37.1202(1)(b); Chiles v. Machine Shop, Inc.; Town v. Michigan Bell Tel. Co.; Kerns v. Dura Mech. Components, Inc.; Fact-specific nature of the inquiry into the qualifications of an employee or applicant for a job; Rourk v. Oakwood Hosp. Corp.; Failure to accommodate claim; MCL 37.1102(2); Buck v. Thomas M. Cooley Law Sch.; MCL 37.1210(15); Whether the defendant-employer should have transferred plaintiff to an open position as an ordinary CO; Tranker v. Figgie Int’l, Inc.; Special Alternative Incarceration (SAI)

[Unpublished opinion.] The court held that the plaintiff did not establish a prima facie case under the PWDCRA because she failed to show a genuine issue of material fact that her disability was unrelated to her ability to perform her job. She also failed to show a genuine issue of material fact as to the defendant’s alleged failure to accommodate. Thus, the court reversed the trial court’s order denying defendant’s summary disposition motion, and remanded. Plaintiff was “separated” from her employment by defendant. Defendant argued on appeal that her disability prevented her “from performing the essential functions of her job, and her disability is related to her ability to perform her job as a SAI corporal.” The court concluded that there was no genuine issue of material fact as to “whether the SAI position required physical activity connected with running and training the prisoners” or that “plaintiff could not perform that job function. In fact, that was precisely the activity from which” she asked to be relieved. While she and the trial court “relied heavily on plaintiff’s work history, that is of little relevance considering her current medical restriction prevents her from performing required tasks of her job in the SAI position.” The trial court also erred in focusing on COs at large. “The proper inquiry is not whether plaintiff could perform the duties of any job at all, such as a general corrections officer, but whether she could perform ‘the duties of a particular job or position.’” The job she held “at the time of the alleged discrimination was that of a SAI corporal. ‘[T]he facts unequivocally demonstrate plaintiff could not perform the acts required for the’ SAI position.” Her condition rendered “her ‘unqualified to perform this particular job,’ which required such high intensity calisthenics.” As to her failure to accommodate claim, the “requested ‘accommodation’ plaintiff seeks is the elimination of essential responsibilities of the position, which is not an accommodation defendant is legally obligated to offer.” While she also contended that “defendant should have accommodated her by transferring her to an open position” as an ordinary CO, “‘the duty to accommodate does not extend to new job placement or transfers to other positions.’”