Judge Stephanie Davis, who was nominated by President Biden to the Sixth Circuit court of appeals, wrote a unanimous opinion that reversed a lower court and gave a fired worker the opportunity to prove to a jury that she was discriminated against based on her disability. The trial court had granted summary judgment against her The September 2024 decision was in Root v Decorative Paint Inc.
What happened in this case?
Tina Root had worked as a production associate for Decorative Paint Inc. (DPI) in Ohio for more than three years. Although she suffers from chronic obstructive pulmonary disease (copd) and asthma, she was able to work in the Rework department, which had limited exposure to paint fumes. In 2020, however, Root was assigned to a section of the plant “closest to the painting oven and its fumes.” After working there for a ten-hour shift, she “began experiencing shortness of breath and difficulties breathing.”
Root gave DPI a note from her doctor explaining the problem and supporting her request to be moved back to the Rework department. Although the PARTIES disagreed on what happened next, Root contends that DPI refused the request and fired her because of her disability. She filed suit against DPI in federal court under the Americans with Disabilities Act (ADA). After discovery, however, the district court found that Root had not shown she could work in the general area of paint fumes, even in the Rework area, and granted summary judgment against her. She appealed to the Sixth Circuit.
How did Judge Davis and the Sixth Circuit Rule and Why is it Important?
Judge Davis wrote a unanimous opinion that reversed the lower court. She ruled that there were “genuine issues of material fact” on Root’s claims of failure to accommodate and firing because of her disability and sent the case back to the lower court so that Root could present her claims to a jury.
Based on a careful review of the record and relevant case law, Davis found that Root had presented evidence suggesting that her disabilities “did not preclude her performing the essential elements of the job” with reasonable accommodations, Davis also concluded that there was a “genuine dispute of material fact” concerning whether DPI “engaged in a good-faith interactive process with Root after she requested her accommodation” or whether she was improperly fired.
Judge Davis’ opinion was obviously important to Tina Root and her effort to obtain justice for the discrimination based on disability that she has raised. In addition, the decision sets an important precedent for courts dealing with ADA claims, particularly in the Sixth Circuit, which includes Tennessee, Michigan, Kentucky and Ohio. It also serves as a reminder of the importance of promptly confirming fair-minded judges to our federal courts.