Beth Carnicella v. Mercy Hospital

2017 ME 161, 168 A.3d 768, 33 Am. Disabilities Cas. (BNA) 962, 2017 WL 3081900, 2017 Me. LEXIS 171
CourtSupreme Judicial Court of Maine
DecidedJuly 20, 2017
StatusPublished

This text of 2017 ME 161 (Beth Carnicella v. Mercy Hospital) is published on Counsel Stack Legal Research, covering Supreme Judicial Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Beth Carnicella v. Mercy Hospital, 2017 ME 161, 168 A.3d 768, 33 Am. Disabilities Cas. (BNA) 962, 2017 WL 3081900, 2017 Me. LEXIS 171 (Me. 2017).

Opinion

MAINE SUPREME JUDICIAL COURT Reporter of Decisions Decision: 2017 ME 161 Docket: Cum-16-528 Argued: June 14, 2017 Decided: July 20, 2017

Panel: SAUFLEY, C.J., and ALEXANDER, MEAD, GORMAN, JABAR, and HJELM, JJ.

BETH CARNICELLA

v.

MERCY HOSPITAL

MEAD, J.

[¶1] Beth Carnicella appeals from a summary judgment entered by the

Superior Court (Cumberland County, Mills, J.) in favor of Mercy Hospital on her

complaint that Mercy discriminated against her in violation of the

Maine Human Rights Act (MHRA). See 5 M.R.S. §§ 4551-4634 (2016). Carnicella

argues that the court erred by determining that she was not a “qualified

individual with a disability” as defined by the MHRA, and by failing to determine

that Mercy did not meet its obligation to identify a reasonable accommodation

for her disability. We affirm the judgment. 2

I. BACKGROUND

[¶2] The following facts are presented in the light most favorable to

Carnicella and are supported by the summary judgment record. See

Trott v. H.D. Goodall Hosp., 2013 ME 33, ¶ 2, 66 A.3d 7.

[¶3] In 2011, Beth Carnicella was hired by Mercy Hospital as a part-time

registered nurse (RN) at Mercy’s Express Care facility in Gorham. On

July 29, 2013, Carnicella was diagnosed with a serious medical condition.

Carnicella requested a leave of absence to begin on August 9, 2013, to have

surgery; she expected to be out of work for only two weeks. In a letter dated

August 1, 2013, Mercy granted her up to ten weeks of leave pursuant to

Maine’s Family Medical Leave statute. See 26 M.R.S. § 844 (2016). The letter

also stated: “Once you are ready to return to work, have your Physician fax . . .

a letter . . . stating the date you’re cleared to return to work.”

[¶4] After her surgery, Carnicella developed complications that affected

her ability to move her left arm properly. On September 20, 2013, Mercy sent

Carnicella a letter reminding her that her leave would expire on

October 18, 2013, and that if she needed an extension, she must file a written

request with the human resources department. The letter also stated in bold

print that she “must have clearance from [her] Physician before [she] return[s] 3

to work.” At that time, Carnicella’s medical provider had not released her to

return to work.

[¶5] Carnicella requested an extension of her leave through

November 18, 2013, which Mercy granted. In the October 10 letter granting

the request, Mercy reiterated the need for Carnicella’s physician to clear her to

work prior to her return. Carnicella was unable to return to work on

November 19 and requested a second extension of her leave. Mercy again

extended Carnicella’s leave and held her position open for her.

[¶6] Based on the information provided to Mercy by Carnicella’s medical

providers, Mercy expected her to return to work on or about

December 31, 2013. Anticipating her return to work, Mercy sent Carnicella a

memorandum dated December 13 regarding any reasonable accommodation

she may need due to a disability. The memorandum explained, among other

things, that it was “up [to her] to alert [her] supervisor or human resources to

[her] need for accommodation.” Carnicella returned the form having checked

a box indicating that she “would like to go forward with the process of

requesting a reasonable accommodation.”

[¶7] On or around December 18, 2013, Mercy received a “Health Care

Provider Questionnaire Regarding Employee Disability and Accommodation” 4

completed by Carnicella’s surgeon. The form asked, among other things,

whether there was a medical reason why Carnicella could not work her normal

twenty-four-hour-per-week schedule, to which Carnicella’s surgeon

responded, “Yes. Cannot lift over 3 pounds or do repetitive computer,

telephone work.” Another question on the form asked: “Will Patient require

any reasonable accommodations to enable him/her to perform the essential

functions of his/her job (please consult enclosed job description). If so, what

accommodations do you recommend?” In response, Carnicella’s surgeon

wrote: “Pending return to work – anticipated return to work 3/15/14.”

[¶8] On January 21, 2014, Carnicella’s primary care physician—who had

taken over management of Carnicella’s medical issues—wrote to Mercy

regarding Carnicella’s return to work. The physician explained:

I know that [Carnicella’s surgeon] recommended that [Carnicella] return to work on March 15, 2014[,] without restrictions. However, in the setting of her left arm weakness and the need for further evaluation, I do not believe that this is an appropriate return to work date. It is always difficult to estimate recovery time, particularly when an evaluation is ongoing. However, I would estimate that she will be able to work full time without restrictions by June 1, 2014.

[Carnicella] loves her job and is highly motivated to return to work. She is understandably frustrated at the thought of having to postpone her return to work date. However, she cannot use her left arm and I have told her that she needs to recover sufficient strength in her arm to do her job safely. I am confident that we will be able 5

to help [Carnicella] achieve this and I would ask that you grant us a little more time . . . .

[¶9] On January 24, 2014, Carnicella met with the director of

Mercy’s human resources department and with Carnicella’s direct supervisor.

At that meeting, Carnicella did not represent that she had work capacity, either

with or without reasonable accommodations. The HR director informed

Carnicella that Mercy would extend her leave until March 15, 2014, and that if

she were unable to return to work by that time, it would attempt to fill her

position due to business needs, but Carnicella could then transition to working

on a per diem basis. Both the HR director and Carnicella’s supervisor assumed

that if and when Carnicella returned to work, it would be with restrictions.

[¶10] In late February 2014, Carnicella’s supervisor was preparing the

schedule for April, May, and June; when she completed the schedule, she was

unable to fill all of the shifts. Mercy contends that the supervisor sent Carnicella

a text message and left her a voicemail asking whether she wanted to be on the

schedule, and that Carnicella never responded. Carnicella, however, asserts

that the supervisor contacted her only to see how she was doing and did not

inquire about adding her to the schedule although Carnicella had been in

regular contact with the supervisor. 6

[¶11] Around March 15, 2014, the HR director left Carnicella a voicemail

asking for a status report concerning her work capacity. Carnicella returned

the HR director’s call and left a voicemail stating that she was not able to return

to work. The HR director interpreted the voicemail to mean that Carnicella did

not want to remain as a per diem employee, and so she processed Carnicella’s

termination from employment. The HR director sent Carnicella a letter dated

March 20, 2014, explaining that her employment would end on March 21 and

inviting her to “please reach out to explore job opportunities” when she was

able to return to work.

[¶12] When Carnicella received the letter, she called her supervisor to

discuss why she had been terminated instead of put on a per diem status. The

supervisor then contacted the HR director and explained that Carnicella wished

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Bluebook (online)
2017 ME 161, 168 A.3d 768, 33 Am. Disabilities Cas. (BNA) 962, 2017 WL 3081900, 2017 Me. LEXIS 171, Counsel Stack Legal Research, https://law.counselstack.com/opinion/beth-carnicella-v-mercy-hospital-me-2017.