Leslie J. Reynard v. Washburn University of Topeka
SocialSecurity
I. Title I mandates employers to reasonably accommodate qualified, disabled employees who request help. Dr. Reynard's lifelong seizure disorder is triggered by certain types of light. Washburn accommodated this limitation for ten years, until 2017 when she was assigned a dangerously lit basement classroom. Washburn forced Dr. Reynard to continue teaching in the assigned room for nearly two months while it delayed her requested room change. Did Washburn's delay in providing her reasonable accommodation violates its obligation to provide it?
II. The Supreme Court found that timing requirements for EEOC filings are non-jurisdictional (Fort Bend County v. Davis, 2019). Dr. Reynard told Washburn about her EEOC charge in April 2018 (opened as a Charge August 2018 due to EEOC backlog). Washburn did not claim a time-bar defense until about April 2022. Dr. Reynard gave evidence Washburn's time calculations were wrong and also argued for consideration of equitable tolling, continuing violations, and hostile environment evidence. Was the lower court's reliance upon an llth-hour affirmative defense of "exhaustion" in granting it summary judgment proper?
Did Washburn's delay in providing Dr. Reynard's reasonable accommodation violate its ADA Title I obligation?