“Confirmed Judges, Confirmed Fears” is a blog series documenting the harmful impact of President Trump’s judges on Americans’ rights and liberties. It includes judges nominated in both his first and second terms.
Trump Judge Joan Larsen wrote a 2-1 ruling upholding the denial of a worker’s claim that his corporate employer had failed to provide a reasonable accommodation for his disability due to epilepsy. Judge Andre Mathis, dissented from the March 2025 Sixth Circuit decision in Woodie v Motorola Solutions Inc.
What happened in this case?
Daniel Woodie worked as a systems technologist for Motorola Solutions from 2013 until he was fired in 2021. In July 2019, he informed his supervisor that he was suffering from nocturnal epilepsy and asked for a travel schedule that was less demanding. He was told that he could submit a formal request for an accommodation to the Office of Human Resources (OHR) but did not do so. Issues arose about problems in communications with customers and coworkers, and Motorola fired him in May, 2021 Although he was able to find another job about a month later, he filed suit against Motorola, contending that they had failed to affirmatively take steps to try to accommodate his disability.
The trial court granted summary judgment to Motorola, focusing on Woodie’s failure to follow specified company procedures concerning accommodation of disabilities. He filed an appeal with the Sixth Circuit.
Why was the decision by Judge Larsen harmful?
Judge Larsen wrote a 2-1 ruling that upheld the decision against Woodie. Although she acknowledged that on “numerous occasions” Woodie had “requested a travel change due to his disability,” she noted that he had “declined” to file a request with OHR for an accommodation pursuant to company procedure. Accordingly, she concluded, Woodie “failed to request an accommodation sufficient to start the interactive process under the ADA” of determining whether an accommodation was achievable. As a result, Larsen wrote, summary judgement against Woodie was proper.
Judge Andre Mathis, who was nominated to the Sixth Circuit by President Biden, strongly dissented. Based on prior precedent, he explained, there were “genuine fact issues” about whether Motorola “failed to engage in the interactive process” concerning accommodation of disabilities that should have precluded summary judgment. Although Woodie had not filed an accommodations request pursuant to company policy, Mathis wrote, a “reasonable jury could find that Woodie’s conversations with his supervisors were accommodations requests.” His failure to follow company procedure may relate to the factual issue of whether Woodie improperly caused a “breakdown” in the accommodations process, Mathis explained, but does not show that Woodie failed even to request an accommodation and start the process.
Larsen’s opinion obviously harms Daniel Woodie’s efforts to get justice for the discrimination that he contends Motorola caused. In addition, by suggesting that an employee must follow specified company procedures in order to even raise a claim of failure to accommodate a disability, the ruling could set a harmful precedent in other disability cases, particularly in the Sixth Circuit, which includes Kentucky, Michigan, Ohio, and Tennessee. The decision also illustrates the importance of our federal courts to health, welfare and justice and the significance of having fair-minded judges on the federal bench.