Heidi Hostettler was hired as an HR Generalist by the College of Wooster in late summer 2013. At the time that she was interviewed and took the position, she was four-months pregnant. Throughout the hiring process, Hostettler was open about her pregnancy[, which the College of Wooster said they could be willing to accommodate]. For the first five months—before her maternity leave—Hostettler’s employment seemed to be a mutually beneficial arrangement. [. . .] Hostettler started her maternity leave at the beginning of February and took her full 12 weeks. She was slated to return to work at the end of April. But as the time to return to work approached, Hostettler experienced severe postpartum depression and separation anxiety. Hostettler’s OB/GYN, Dr. David Seals, testified that “she had one of the worst cases of separation anxiety” that he had ever seen. Seals explained that she did not seem like herself and that she cried during almost every appointment with him. He prescribed her an antidepressant. Seals also thought that it would be a bad idea for Hostettler to return to work right away, and testified that he believed that “it was medically necessary that [Hostettler] could work a reduced schedule.” He suggested that she return to work on a part-time basis for the “foreseeable future.”. . . Concerned that she could not return to work, Hostettler met with her direct supervisor, Marcia Beasley, and explained how she was doing and that she would need more time before coming back. According to Hostettler, Beasley was “sympathetic and understood.” [. . .] In the beginning of May, [w]hen Hostettler returned to work, Beasley recommended that. . . Hostettler work five half days a week [. . .] Wooster informed Hostettler that it would accommodate her part-time schedule until June 30, at which time she should submit an updated certification from her doctor. [. . .] The parties disagree over what happened during the following two months. Hostettler continued to suffer from depression and anxiety. And if she had to work much later than noon—her modified stop page 759time—she would have panic attacks, during which she would have difficulty breathing, thinking, and even walking. But with an accommodated schedule, Hostettler contends that she was able to do everything required of her position. [. . .] Apparently, Beasley agreed with much of what Hostettler. . . concluded [and one of her colleagues confirmed]. [. . .] Throughout Hostettler’s time at Wooster, there had been no complaints about her work or conduct. Beasley stated that Hostettler never failed to perform any responsibility or finish any assignment in a timely manner. And her first evaluation, done in June or July of 2014—shortly before Hostettler was fired—contained no negative feedback but instead concluded that “Heidi is a great colleague and a welcome addition to the HR team!” At the same time, however, Beasley felt that Hostettler’s modified schedule put a strain on Beasley and the rest of the department. She testified that during that time, Hostettler did not perform critical functions of her job, such as filling job openings, and leading trainings and lunch programs. As a result, Beasley was “just running from one thing to another to get things done” and was “really overwhelmed and left without anyone in the office to help with responsibilities and tasks that came up.” She also contended that work in the department was left unfinished or ignored. And Beasley was concerned that an upcoming online benefits project would leave the HR team even more short-staffed. But when pressed to identify any specific responsibilities or assignments that were not completed, Beasley repeatedly was unable to name any. [. . .] At the conclusion of the first two weeks of July, Seals submitted an updated medical certification, in which he explained that Hostettler should continue to work half-time and estimated that she might return to full-time employment at the beginning of September. Hostettler contends, however, that on the day after Seals submitted the medical certification, she followed up with Beasley, asking again about extending her hours from 8:00 a.m. to 2:00 p.m. Beasley never responded. The next day, Beasley fired Hostettler. Beasley sent her a letter, stating that because her updated medical certification required her to work half-time, she was “unable to return to [her] assigned position of HR Generalist in a full time capacity” and was being terminated. A few weeks later, Beasley hired a temporary clerical employee to handle some of the administrative work in the department. But that employee did not do any of the tasks that the department required an HR Generalist to complete. As a result, Hostettler’s firing left the department with fewer resources for employee relations, training, and hiring. It was not until October of that year that Wooster hired Hostettler’s replacement—a man. Hostettler sued Wooster, claiming violations of the ADA, the FMLA, Title VII’s prohibition against sex discrimination, and corresponding Ohio state laws. Wooster moved for summary judgment on all claims and Hostettler moved for partial summary judgment on her ADA claim. The district court denied Hostettler’s motion and granted Wooster’s motion on all of Hostettler’s claims.

Case Questions

Do you believe the employer made a good-faith effort to reasonably accommodate the employee? Can you imagine a reasonable accommodation the College of Wooster otherwise might have been able to provide for Hostettler? Why might it be in the employer’s best interest to provide reasonable accommodations to people with disabilities, regardless of whether there is a requirement to provide an accommodation?