## Facts

- Mayra F. Peña worked for Honeywell International, Inc. as a machine operator/associate assembler at its Cranston, Rhode Island facility starting around 2008.
- In 2012, Honeywell adopted a cross-training approach so production and assembly employees could work in multiple departments, including the molding department.
- Peña had a history of medical leave related to mental-health conditions, including leave for seasonal depression from late 2012 into January 2013.
- After returning in January 2013, Peña worked for about a month, including assignments in the molding department, and reported that working there worsened her anxiety and was emotionally harmful.
- In late February 2013, Peña asked not to work in the molding department; Honeywell requested medical documentation.
- Peña provided a March 4, 2013 letter from her physician stating she reported increased anxiety when working in molding and could work in other departments, without providing diagnosis or an explanation tied to job requirements.
- Honeywell found the documentation inadequate and told Peña on March 8, 2013 that she must work in molding or go home; Peña left and did not return.
- Honeywell attempted to contact Peña and sought further documentation; on June 17, 2013, Honeywell terminated her for job abandonment.
- On September 20, 2013, Peña applied for SSDI benefits, asserting under oath that she had been totally disabled and unable to work since March 8, 2013; an ALJ later found her totally disabled as of that date.
- Peña sued in April 2015 under the ADA and Rhode Island law, alleging disability discrimination (termination), failure to accommodate, and retaliation.

## Issues

1. Whether Peña’s sworn SSDI position and the ALJ’s finding that she was totally disabled as of March 8, 2013 conflicted with ADA claims requiring proof she could perform essential job functions with or without reasonable accommodation.
2. Whether Peña provided a sufficient explanation, as required by Cleveland, to allow a reasonable juror to reconcile her SSDI total-disability statements with her ADA theory that she could have worked if reassigned away from molding.

## Decision

- The First Circuit affirmed summary judgment for Honeywell on all claims.
- The court held Peña did not satisfy Cleveland’s requirement to explain the inconsistency between her SSDI representations of total disability and her ADA position that she could work with reasonable accommodation.
- The court relied heavily on Peña’s deposition testimony, where she affirmed her SSDI assertion that she was unable to work and did not give an explanation connecting both positions in a way a reasonable juror could accept.
- Because she failed to create a triable issue that she was a “qualified individual” under the ADA during the relevant period, her accommodation, discriminatory-termination, and retaliation theories could not proceed.

## Legal Principles

- An ADA plaintiff is not automatically barred by having sought or received SSDI benefits, but must explain any apparent conflict between a claim of total disability and an ADA claim that the plaintiff could work with reasonable accommodation.
- Under Cleveland, the plaintiff must provide an explanation sufficient for a reasonable juror to conclude that, even accepting the earlier disability statements as truthful or made in good faith, the plaintiff could still perform essential job functions with or without reasonable accommodation.
- Where the plaintiff’s sworn SSDI statements and testimony confirm an inability to work at all as of the same date central to the ADA claims, and the plaintiff offers no coherent reconciliation (e.g., different time period, different job demands, or different standards), summary judgment is proper.

## Conclusion

The First Circuit held that Peña’s ADA claims failed because she did not adequately reconcile her sworn SSDI position of total disability beginning March 8, 2013 with her ADA assertion that she could have continued working if accommodated by reassignment away from the molding department.


Peña v. Honeywell Int'l, Inc., 923 F.3d 18 (1st Cir. 2019)