The recent Sixth Circuit opinion in Hostettler v. The College of Wooster, No. 17-3406 (6th Cir. July 17, 2018), is a cautionary tale for employers faced with a full-time employee seeking a modified work schedule as an accommodation for a disability under the Americans with Disabilities Act (ADA).
An HR Generalist for the College, Hostettler was unable to return to work full time after the conclusion of her 12 weeks of maternity leave because of postpartum depression and separation anxiety. The district court granted summary judgment to the College, finding that full-time work was an essential function of the position and that Hostettler was not a qualified individual under the ADA because she could not perform that essential function.
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