Laguana v. United Airlines, Inc. – Do It For The Caselaw

Holding: The Ninth Circuit affirmed the district court's grant of summary judgment, holding that the airline satisfied its ADA obligation to engage in an interactive process by granting the employee's only requested accommodation.
Standard: de novo review of summary judgment
Vote: The panel unanimously concluded the case was suitable for decision without oral argument.
Practical effect: Employers may satisfy their interactive process obligation under the ADA if they grant the specific accommodation requested by the employee, even if the employee later claims other accommodations were needed but never requested.

The Ninth Circuit affirmed a district court's grant of summary judgment in an Americans with Disabilities Act case. The court held that the airline satisfied its obligation to engage in an interactive process by granting the employee's only requested accommodation.

Background

Joseph Laguana, an employee of United Airlines, requested and received medical leave due to his asthma. After exhausting his paid leave, he went on unpaid medical leave until he was terminated over two years later. Laguana sued United under the Americans with Disabilities Act, alleging the airline failed to provide reasonable accommodations and failed to engage in an interactive process.

The court’s reasoning

The court reviewed the grant of summary judgment de novo. The only issue on appeal was whether United violated the ADA by failing to provide reasonable accommodations beyond extended medical leave and by failing to engage in an interactive process. Under the ADA, once an employee requests an accommodation, the employer must engage in an interactive process to determine the appropriate reasonable accommodation. However, United granted Laguana’s only accommodation request, which was extended medical leave. Laguana never requested any other accommodations. The court found that United satisfied its obligation to engage in the interactive process because at each step of the way, it extended Laguana’s leave, which was the only accommodation requested.

What it means going forward

Employers may satisfy their interactive process obligation under the ADA if they grant the specific accommodation requested by the employee, even if the employee later claims other accommodations were needed but never requested.