Tafolla v. Heilig

What the court decided

A clerk typist's doctor wrote that she could not lift more than five pounds and, on a separate line, that she should do no bending or pushing. Her supervisors applied only the five-pound limit and kept giving her archiving work, then told her she would have to go on medical leave unless she could work with no restrictions. The court held that a jury could find that archiving was not an essential function, that the employer never granted the accommodation her doctor described, that the employer rather than the employee ended the interactive process, and that forcing her onto medical leave, which led to her termination a year later, was retaliation. A forced leave "could well dissuade a reasonable worker" from complaining.

Who won

The employee won this round. The Second Circuit vacated summary judgment on her accommodation and retaliation claims under the ADA and the State law and sent them back, over a judge who would have held that she was responsible for the breakdown. It affirmed dismissal of a claim she had abandoned.

Why it matters for workers with a medical condition

If your employer reads your doctor's note narrowly and never asks the doctor what was meant, that can be evidence it did not accommodate you. And being pushed onto leave after asking for help can itself be retaliation.

Key passage: 80 F.4th at 119–27.

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