Discrimination under the Americans with Disabilities Act (ADA) (42 USC §§ 12101–12213); Legal frameworks for establishing proof of discrimination; Indirect method; McDonnell Douglas Corp. v. Green; Direct method; Ferrari v. Ford Motor Co.; Monette v. Electronic Data Sys. Corp.; Kleiber v. Honda of Am. Mfg., Inc.; Martinez v. Cracker Barrel Old Country Store, Inc.; Whether plaintiff was “disabled” under the ADA; §§ 12102(1)(A) & 12102(2); 29 CFR § 1630.2(i)(2); Whether she was “otherwise qualified for her position”; Mosby-Meachem v. Memphis Light, Gas & Water Div.; Kiphart v. Saturn Corp.; §§ 1630.2 (n)(1) & (3); Hoskins v. Oakland Cnty. Sheriff’s Dep’t; EEOC v. Ford Motor Co.; Williams v. AT&T Mobility Servs.; Whether defendant was willing “to engage in an interactive process”; Title VII sex & pregnancy discrimination claim; Demyanovich v. Cadon Plating & Coatings, L.L.C.; Seeger v. Cincinnati Bell Tel. Co.; Family & Medical Leave Act (FMLA) claims; 29 USC §§ 2601–2654; Dobrowski v. Jay Dee Contractors, Inc.; Sorrell v. Rinker Materials Corp.

The court held that the defendant-employer (Wooster) was improperly granted summary judgment on plaintiff-Hostettler’s ADA claim where the district court erroneously applied the indirect method instead of the direct method to determine whether she made her prima facie case where Wooster rescinded a reasonable accommodation. Hostettler worked as a HR Generalist for Wooster. After the birth of her child, she suffered from depression and separation anxiety. Her 12-week maternity leave was extended under a doctor’s certification, and she returned to work part-time until she was fired. The district court granted Wooster summary judgment based on its conclusion that she failed to establish a prima facie case under the ADA where “she could not meet an essential function of the position—full-time work—and so was not otherwise qualified for the job.” The court concluded that the district court applied the wrong legal standard when it used the burden-shifting approach of McDonnell Douglas. Instead, the court held that it should have applied the direct method given that Wooster rescinded the accommodations it had made for Hostettler. Her supervisor “admitted that Hostettler was fired solely because the college determined that it no longer could accommodate her modified schedule.” Applying the direct method to Hostettler’s ADA claim, the court held that she qualified as an “individual with a disability.” The decisive inquiry was whether “Hostettler was otherwise qualified for her position.” Although the district court ruled that she was not, the court held that summary judgment was not appropriate where both parties offered evidence that raised genuine issues whether she met this requirement. Also, the district court ruled that “as a matter of law, working full time was an essential function of the position.” However, the court held that, on its own, “full-time presence at work is not an essential function. An employer must tie time-and-presence requirements to some other job requirement.” Wooster was required to “explain why Hostettler could not complete the essential functions of her job unless she was present 40 hours a week.” Fact questions also remained as to whether Wooster was “willing to engage in the interactive process” to “‘identify the precise limitations resulting from the disability and potential reasonable accommodations that could overcome those limitations.’” The court also held that summary judgment was improper on Hostettler’s Title VII sex- and pregnancy-discrimination claim and her FMLA claims.