思拉舍诉UAB医院管理有限责任公司案

Kathryn Thrasher, a registered nurse suffering from pulmonary alveolar proteinosis—a chronic lung disease causing headaches, fatigue, and breathing difficulties—filed an employment discrimination lawsuit against UAB Hospital Management LLC and the Board of Trustees of the University of Alabama at Birmingham. She alleged that the defendants discriminated against her based on her disability in violation of the Rehabilitation Act of 1973. The case was filed on October 14, 2022, in the U.S. District Court for the Northern District of Alabama. On September 30, 2024, U.S. Magistrate Judge Staci G. Cornelius issued a memorandum opinion and order denying UAB's motion for summary judgment, ruling that genuine disputes of material fact existed regarding whether UAB failed to accommodate Thrasher's disability.

On September 30, 2024, the U.S. District Court for the Northern District of Alabama denied UAB's motion for summary judgment. The court found that genuine disputes of material fact existed, precluding judgment as a matter of law. The case was permitted to proceed to trial on the merits of Thrasher's disability discrimination claims under the Rehabilitation Act.

The central dispute was whether UAB Hospital discriminated against Kathryn Thrasher based on her disability in violation of the Rehabilitation Act of 1973. Specifically, the parties disputed whether providing Thrasher with a leave of absence relieved UAB of its obligation to provide reasonable accommodation for her chronic lung condition, and whether patient care constituted an essential function of her perioperative services nurse position that she could not perform. The case also involved factual disputes regarding whether UAB's employment actions constituted unlawful discrimination rather than legitimate business decisions.

The case reinforces the protections afforded to employees with disabilities under the Rehabilitation Act of 1973, particularly in the healthcare employment context. The court's denial of summary judgment underscores that employers cannot rely solely on providing leave of absence as a substitute for exploring reasonable accommodations. The ruling affirms that factual disputes regarding whether an employee can perform essential job functions with accommodation must be resolved by a jury, not decided at the summary judgment stage. This decision may influence how healthcare employers evaluate accommodation requests from employees with chronic conditions and serves as a reminder that disability discrimination claims require careful factual examination.