## Facts

- The College of Wooster hired Heidi Hostettler in 2013 as an HR Generalist while she was pregnant.
- The college allowed Hostettler 12 weeks of unpaid maternity leave under a policy extending FMLA-type leave to new employees.
- Near her return, Hostettler experienced postpartum depression and separation anxiety; her physician certified that a reduced schedule was medically necessary.
- Hostettler returned on a part-time schedule (five half-days per week) with supervisory approval; she sometimes worked from home, a practice used in the department.
- Hostettler and a coworker stated she completed her duties and received no complaints; her supervisor acknowledged she did not miss responsibilities or fail to timely finish assignments.
- The college asserted the reduced schedule strained the department and prevented Hostettler from performing essential functions, but the supervisor could not provide specific examples of unfinished or ignored work.
- After an updated medical certification indicating a possible full-time return in September, the supervisor terminated Hostettler because she could not work full-time.

## Issues

1. Whether full-time, in-office work was an essential function of the HR Generalist position as a matter of law, making Hostettler not a “qualified individual” under the ADA.
2. Whether factual disputes existed about reasonable accommodation (part-time schedule) and whether termination constituted disability discrimination under the ADA.
3. Whether summary judgment was properly granted on Hostettler’s related Title VII, FMLA, and parallel Ohio discrimination claims.

## Decision

- The Sixth Circuit reversed the district court’s grant of summary judgment and remanded for further proceedings.
- The court held the district court erred by treating full-time work as an essential function as a matter of law.
- The court found genuine disputes of material fact regarding whether Hostettler could perform the job’s essential functions with a part-time schedule and whether the college unlawfully ended that accommodation.
- The court’s reversal required reconsideration of related federal and state-law claims tied to the same factual record.

## Legal Principles

- Under the ADA, a “qualified individual” is one who can perform the essential functions of the position with or without reasonable accommodation.
- Whether a job function is “essential” is a fact-specific inquiry; an employer’s label or preference for full-time presence does not conclusively establish essentiality.
- Relevant factors include the employer’s judgment, written job descriptions, consequences of nonperformance, and actual experience of employees performing the job.
- The ADA expressly contemplates reasonable accommodations such as “part-time or modified work schedules.”
- On summary judgment, courts must view evidence in the nonmovant’s favor and may not resolve credibility disputes; contested evidence about performance and workplace impact can preclude judgment as a matter of law.

## Conclusion

The Sixth Circuit held that a preference for full-time, on-site work does not automatically make full-time presence an ADA essential function, and that disputed evidence about Hostettler’s performance and the feasibility of a part-time schedule required a jury trial rather than summary judgment.


Hostettler v. Coll. of Wooster, 895 F.3d 844 (6th Cir. 2018)