Leslie J. Reynard v. Washburn University of Topeka
SocialSecurity
Did Washburn's delay in providing Dr. Reynard's reasonable accommodation violate its ADA Title I obligation?
QUESTIONS PRESENTED I. ADA 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 nonjurisdictional (Fort Bend County v. Davis. 2019). Dr. Reynard told Washburn of her EEOC Inquiry 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 11th-hour affirmative defense of "exhaustion" in granting it summary judgment proper? ii ,