Umble v. Arrowhead Community Hospital & Medical Center
Docket: No. 99-17300; D.C. CV-97-01360-RGS
Court: Court of Appeals for the Ninth Circuit; April 25, 2001; Federal Appellate Court
Linda Umble filed a lawsuit against Arrowhead Community Hospital and Baptist Hospital and Health Systems under the Americans with Disabilities Act (ADA). The district court granted summary judgment in favor of Arrowhead, affirming that Umble's termination did not violate the ADA. The court found that Arrowhead was unaware that complaints regarding Umble's behavior were related to her migraine condition, thus imposing no duty to accommodate her disability. Even if an accommodation duty existed, Umble hindered the interactive process by rejecting a leave of absence offer and failing to request alternative accommodations. She consistently claimed her job performance was satisfactory and did not require any accommodations for her return to work. Additionally, the court determined that Umble did not properly raise a separate failure-to-accommodate claim concerning her attendance issues from January, as her complaint primarily focused on her termination in September 1996. Although she referenced January's events to support her wrongful termination claim, she did not assert a failure-to-accommodate argument as an independent basis for liability. Consequently, the grant of summary judgment to the defendants was affirmed. The decision is not intended for publication and cannot be cited in future cases, and the court did not address Umble's argument regarding the lack of an ADA policy or posted notices since no duty to accommodate was established.