Judge John Murphy, nominated by President Biden to the federal district court for the Eastern District of Pennsylvania, denied a county’s motion for summary judgment and ruled that a fired corrections officer could try to prove her disability discrimination case at trial. The July 2024 decision was in Parrish v County of Delaware..
What is the background of this case?
Niquine Parrish worked as a corrections officer in a corrections facility in Delaware County for more than fifteen years. She developed several serious medical conditions, including herniated discs and knee osteoarthritis, which limited the work she could do. For several years, when the facility was run by a private contractor, she worked under a medical accommodation that limited her to eight-hour days with no mandatory overtime.
In 2022, all employees were notified that Delaware County itself was to take over the facility, that their jobs would be terminated, and the County would determine whether to hire them again. Because of staffing shortages, the job description for corrections officers stated that they must be available for mandatory overtime. To “save her job,” Parrish stated that she would be so available. She was hired and, as other employees sometimes did, paid others to work her overtime hours. Hoping to return to her former accommodated status, Parrish requested an accommodation under the ADA, and provided a note from a doctor stating that she could not work more than 8 hours per day. The County refused her request and would not discuss other possible accommodations’, taking the position that being available for mandatory overtime was an “essential” part of the job.
The County fired Parrish shortly thereafter. She then filed suit in federal court, claiming failure to accommodate under the ADA and retaliation. Discovery went forward and the County filed a motion for summary judgment on her complaint. . .
How did Judge Murphy Rule and Why is it Important?
After carefully considering the record and relevant case law, Judge Murphy denied the County’s motion for summary judgment. He ruled that the case should go forward for trial, where Parrish could try to prove her claims.
A key issue in the case concerns the County’s assertion that being able to work overtime is an “essential” function of the job, and that if Parrish cannot do so, she is not qualified for the job and cannot bring an ADA claim. Judge Murphy explained that it is not “conclusive” for an employer like the County to simply claim that a job function is essential, and that there were material factual issues in dispute on the subject, which a jury should resolve at trial.
Murphy found a number of other issues as to which there was a genuine dispute of material fact, precluding summary judgment. These included whether the County violated the ADA by failing to offer Parrish a reasonable accommodation, whether it failed to engage in a “good faith interactive process to identify accommodations,” and whether the County’s reason for terminating Parrish were a pretext for retaliation. He concluded that all of her claims should be considered at trial before a jury.
Judge Murphy’s decision is obviously important to Niquine Parrish and her effort to obtain justice for the discrimination that she contends she suffered. The ruling also sets a precedent that may be important in other cases, especially when an employer contends that a person cannot bring an ADA claim because they cannot perform a function that the employer contends is “essential” for the job. In addition, the decision serves as a reminder of the importance of prompt confirmation of fair-minded judges to our federal courts.