Case Citation
Legal Case Name

E.E.O.C. v. McLEOD HEALTH, INC. Case Brief

United States Court of Appeals, Fourth Circuit2019
914 F.3d 876

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Case Brief Summary & Legal Analysis

General Brief
4 min read

tl;dr: An employer required a long-tenured employee with a known mobility impairment to undergo a medical exam after several falls, ultimately firing her. The court reversed summary judgment for the employer, finding jury questions as to whether the exam was justified and whether the employee was qualified.

Legal Significance: This case clarifies the ADA’s “business necessity” standard for mandatory medical exams, emphasizing that an employer’s belief must be based on objective evidence available before the exam, and that an employee’s long history of successful performance is a key consideration.

E.E.O.C. v. McLEOD HEALTH, INC. Law School Study Guide

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Case Facts & Court Holding

Key Facts & Case Background

Cecilia Whitten, an employee at McLeod Health for 28 years, had a congenital disability affecting her mobility, which caused her to fall occasionally throughout her life. Despite this, she satisfactorily performed her job as an editor for the company newsletter, which involved traveling between McLeod’s campuses. After Whitten fell three times in four months (only one of which occurred at work and resulted in no significant injury), her manager, who had also noted performance issues and perceived sluggishness, reported the falls. Based on this report, McLeod’s occupational health department required Whitten to undergo a fitness-for-duty exam to ensure she could travel safely. This led to a subsequent functional-capacity exam (FCE), which concluded she was a high fall risk. The FCE was based on flawed assumptions about her job duties, such as overestimating lifting requirements. McLeod determined that no reasonable accommodation would allow her to perform what it considered the essential function of traveling between campuses. After placing her on unpaid leave, McLeod terminated her employment. The EEOC sued on Whitten’s behalf, alleging an illegal medical exam and wrongful discharge under the Americans with Disabilities Act (ADA). The district court granted summary judgment to McLeod.

Court Holding & Legal Precedent

Issue: Did the employer violate the ADA by requiring an employee to undergo a medical examination where there were genuine disputes of material fact as to whether mobility was an essential job function and whether the employer had a reasonable, objective belief that the employee posed a direct threat to herself?

Yes. The Fourth Circuit reversed the grant of summary judgment, holding that Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu fu

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Legal Issue

Did the employer violate the ADA by requiring an employee to undergo a medical examination where there were genuine disputes of material fact as to whether mobility was an essential job function and whether the employer had a reasonable, objective belief that the employee posed a direct threat to herself?

Conclusion

This case serves as a critical reminder that employers must meet a Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exerc

Legal Rule

Under the ADA, 42 U.S.C. § 12112(d)(4)(A), an employer may require an Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu fugiat nulla pariatur. Excepteur sint occaecat cupidatat non proident, sunt in culpa qui officia deserunt mol

Legal Analysis

The court's analysis focused on two key factual disputes that precluded summary Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu fugiat nulla pariatur. Excepteur sint occaecat cupidatat non proident, sunt in culpa qui officia deserunt mollit anim id est laborum. Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu fugiat nulla pariatur. Excepteur sint occaecat cupidatat non proident, sunt in culpa qui officia deserunt mollit anim id est laborum. Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu fugiat nulla pariatur. Excepteur sint occaecat cupidatat non proident, sunt in culpa qui officia deserunt mollit anim id est laborum. Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco labo

Flash-to-Full Case Opinions

Flash Summary

  • An employer violates the ADA by requiring a medical exam unless
Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu fugiat nulla pariatur. Excepteur sint occaecat cupidatat non proident, sunt in culpa qui off

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