Equal Employment Opportunity Commission v. William Beaumont Hospital d/b/a Beaumont Health System

CourtDistrict Court, E.D. Michigan
DecidedNovember 19, 2025
Docket4:23-cv-11560
StatusUnknown

This text of Equal Employment Opportunity Commission v. William Beaumont Hospital d/b/a Beaumont Health System (Equal Employment Opportunity Commission v. William Beaumont Hospital d/b/a Beaumont Health System) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Equal Employment Opportunity Commission v. William Beaumont Hospital d/b/a Beaumont Health System, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

EQUAL EMPLOYMENT Case No. 23-cv-11560 OPPORTUNITY COMMISSION, Hon. F. Kay Behm Plaintiff, United States District Judge v.

WILLIAM BEAUMONT HOSPITAL d/b/a BEAUMONT HEALTH SYSTEM,

Defendant. ___________________________ /

OPINION AND ORDER DENYING DEFENDANT’S MOTION FOR RECONSIDERATION (ECF No. 28)

I. PROCEDURAL HISTORY This is an employment case brought by the Equal Employment Opportunity Commission (“EEOC” or “the Commission”) on June 28, 2023, on behalf of Megan Shefke (“Shefke”), a former Unit Shift Lead (Charge Nurse) at William Beaumont Hospital (“Beaumont”) in Wayne, Michigan. Shefke was employed by Beaumont from May 2017 to January 2020, when she resigned to take a different job. The EEOC alleges that Beaumont violated the Americans with Disabilities Act (“ADA”) by failing to reassign Shefke to a vacant position for which she was qualified. The parties brought competing motions for summary

judgment, and both were granted in part and denied in part, narrowing the scope of the issues for trial. ECF No. 24. Defendant now brings a motion for reconsideration of the court’s

order on the parties’ motions for summary judgment, and asks that the court enter judgment in its favor. ECF No. 28 (Defendant’s Motion for Reconsideration). The court ordered a response, which was received at

ECF No. 30, and finds that no oral argument is necessary to resolve the issues presented. LR 7.1(h)(3). For the reasons explained below, the motion for reconsideration is

DENIED. II. FACTUAL BACKGROUND The primary dispute on this motion, as presented by Defendant, is

that Shefke did not provide Beaumont with updated medical documentation until June 2019, and thus Beaumont had no duty to place her in any of the three open positions prior to that time. Because

all three positions were filled before Shefke provided updated medical documentation, Beaumont says it is entitled to judgment and reconsideration of the court’s prior opinion. The relevant facts were set out in some detail in the court’s prior opinion, and to prevent needless

repetition, the court assumes familiarity with that opinion. See ECF No. 24; Equal Emp. Opportunity Comm’n v. William Beaumont Hosp., No. 23-CV-11560, 2025 WL 1831056 (E.D. Mich. July 2, 2025). For

purposes of this motion only, the court highlights a few key facts and disputes of fact. One, there is no dispute that each of the three remaining positions

that Shefke claims she should have been transferred to or considered for had been filled prior to the time Shefke provided Beaumont with new medical documentation in June 2019. However, there is also no

dispute that Shefke had submitted applications to all three of those positions months before, while they were advertised as vacant by Beaumont (there is a dispute as to whether one position was in fact

vacant). See ECF No. 24, PageID.756. The court has also already indicated that a jury could find that Shefke had said enough to Beaumont to put her employer on notice that she was seeking a transfer

as an accommodation at the time she applied to those positions. E.g., ECF No. 24, PageID.817-22. Two, there is no dispute that Beaumont was already aware that

Shefke had Fabry disease, was thus disabled under the meaning of the ADA, because she had previously provided them medical documentation and received reasonable accommodations. ECF No. 24, PageID.742-43.

For example, Beaumont had already approved one request for reduced hours. Id. Three, at least some evidence shows that Beaumont did ask

Shefke for updated medical documentation several times as part of the transfer process, which perhaps suggests that Beaumont sought to impose a requirement for her to provide them documentation at some

point prior to being transferred. ECF No. 17-9, PageID.138 (“Please have your health care provider complete the attached Medical Inquiry form to assist us with that process”); id. at PageID.137 (“The request to

have a reduction in your hours from 32 down to part-time as a result of needing an accommodation for your disability is a new request that we need documentation for.”).

However, there is also evidence indicating that Shefke was never told she needed to provide Beaumont with medical documentation prior to being transferred or prior to being considered for a transfer. ECF No. 17-18, PageID.237 (Fildew1 Dep. at 55-56) (“Q: So she could still apply

so long as she was – from your perspective, so long as she was keeping you informed of job openings that she was interested in, it wasn’t as important to have the form in hand yet . . . ?” “A: Correct. So you’re

always eligible to apply, right, . . .”). For example, when Shefke informed Beaumont that she had applied to an open position, Beaumont HR made no mention of requiring medical paperwork to be completed

before Shefke could be interviewed or considered for the position. ECF No. 18-11, PageID.432 (“I have reached out to the manager over recruitment at the Beaumont Service Center so they are in the loop that

you[’re] interested in transferring.”); see also ECF No. 18-12, PageID.436 (“Megan is a FT [full time] Nurse here at Wayne and looking to go PT [part time] as soon as possible as she is no longer able

to continue fulltime. If she could be scheduled for interviews for anything she meets the qualifications for that would be helpful.”); ECF No. 18-12, PageID.435 (“Kevin-can you please review Megan’s app and

send her to the hiring manager if she meets the requirements?”); see

1 Kelly Fildew is a former HR administrator for Beaumont. also generally ECF No. 30, PageID.892 (communications from

Beaumont to Shefke). III. STANDARD OF REVIEW Under Eastern District of Michigan Local Rule 7.1(h)(2) and LCrR

12.1, a party may file a motion for reconsideration of a non-final order only if: (A) the court made a mistake, correcting the mistake changes the outcome of the prior decision, and the mistake was based on the

record and law before the court at the time of its prior decision, (2) an intervening change in controlling law warrants a different outcome, or (3) new facts warrant a different outcome and the new facts could not

have been discovered with reasonable diligence before the prior decision. E.D. Mich. L.R. 7.1(h)(2). “Motions for reconsideration of non- final orders are disfavored.” Id.

Notably, a motion for reconsideration, much like a motion to alter or amend a judgment, is thus not for the purpose of “proffer[ing] a new legal theory or new evidence to support a prior argument when

the legal theory or argument could, with due diligence, have been discovered and offered during the initial consideration of the issue.” McConocha v. Blue Cross Blue Shield Mut. of Ohio, 930 F. Supp. 1182, 1184 (N.D. Ohio 1996). Nor is it an appropriate vehicle for raising new

facts or arguments. Sault Ste. Marie Tribe of Chippewa Indians v. Engler, 146 F.3d 367, 374 (6th Cir. 1998) (motions under Fed. R. Civ. P. 59(e) “are aimed at reconsideration, not initial consideration”). “A

motion for reconsideration ‘addresses only factual and legal matters that the court may have overlooked . . . .’ It is improper on a motion for reconsideration to ‘ask the court to rethink what [it] had already

thought through—rightly or wrongly.’” Carter v. Robinson, 211 F.R.D. 549, 550 (E.D. Mich. 2003) (quoting Above the Belt, Inc. v. Mel Bohannan Roofing, Inc., 99 F.R.D. 99, 101 (E.D. Va. 1983). “It is an

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Equal Employment Opportunity Commission v. William Beaumont Hospital d/b/a Beaumont Health System, Counsel Stack Legal Research, https://law.counselstack.com/opinion/equal-employment-opportunity-commission-v-william-beaumont-hospital-dba-mied-2025.