Wyatt Employment Law Report


Sixth Circuit Issues Ruling Regarding Modified Work Schedules

By Amanda Warford Edge

adult-africa-african-1089550 (1)Last week, the Sixth Circuit issued an opinion in Hostettler v. College of Wooster, — F.3d — (6th Cir. July 17, 2018), reminding employers that determining the essential functions of a position is a highly fact-specific endeavor.  In that case, the College of Wooster had hired Heidi Hostettler in 2013 when she was four months pregnant.  She worked as a full-time HR Generalist.  After giving birth to her child, Hostettler experienced severe postpartum depression and separation anxiety.  As a result, her doctor determined it was medically necessary that Hostettler work a reduced schedule, working on a part-time basis for the “foreseeable future.”  After two months of working a reduced schedule, Hostettler was fired for being “unable to return to [her] assigned position of HR Generalist in a full time capacity.”

Hostettler brought suit under the Americans with Disabilities Act (“ADA”)¹,  Continue reading