Mammone v. President & Fellows of Harvard College

847 N.E.2d 276, 446 Mass. 657, 17 Am. Disabilities Cas. (BNA) 1680, 2006 Mass. LEXIS 202
CourtMassachusetts Supreme Judicial Court
DecidedMay 12, 2006
StatusPublished
Cited by17 cases

This text of 847 N.E.2d 276 (Mammone v. President & Fellows of Harvard College) is published on Counsel Stack Legal Research, covering Massachusetts Supreme Judicial Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mammone v. President & Fellows of Harvard College, 847 N.E.2d 276, 446 Mass. 657, 17 Am. Disabilities Cas. (BNA) 1680, 2006 Mass. LEXIS 202 (Mass. 2006).

Opinions

Cordy, J.

On March 7, 2003, Harvard University terminated the seven-year employment of Michael Mammone. Mammone, who suffers from bipolar disorder and claims that he was terminated due to his mental disability, brought suit against the President and Fellows of Harvard College (university) under the Commonwealth’s employment discrimination statute, G. L. c. 151B, § 4 (16),1 and Equal Rights Act, G. L. c. 93, § 103.2 Relying principally on this court’s decision in Garrity v. United Airlines, Inc., 421 Mass. 55 (1995) (Garrity), a judge in the Superior Court granted the university’s motion for summary judgment, concluding that, because of his misconduct in the workplace, Mammone could not reasonably expect to prove that he was a “qualified handicapped person,” a required showing for protection under both statutes.

A “qualified handicapped person” is one “who is capable of performing the essential functions of a particular job, or who would be capable of performing the essential functions of a particular job with reasonable accommodation to his handicap.”3 G. L. c. 151B, § 1 (16). In granting summary judgment, the judge found that the workplace misconduct that led to Mam-[659]*659mane’s termination was egregious and sufficiently inimical to the interests of his employer that it would have resulted in the termination of a nonhandicapped employee. In these circumstances, the judge concluded, it would be impossible for Mammone to show that he was “capable of performing the essential functions” of his job. Mammone appealed, and we transferred the case to this court on our own motion.

Mammone contends that the reasoning of Garrity — that a handicapped employee who engages in egregious workplace misconduct can be held to the same standard as a nonhandicapped employee who engages in similar misconduct — should be strictly limited to cases involving misconduct resulting from drug or alcohol dependence (as opposed to other handicaps). We conclude otherwise. Nothing in the language we used in Garrity suggests that our holding was meant to be so narrow, and we do not discern any legislative intent to create a distinction that would provide different protections against discrimination to persons suffering from one form of handicap (alcoholism) than the protections provided to persons suffering from other disabilities. Because we conclude that Garrity applies to all employment discrimination cases brought under G. L. c. 151B, § 4 (16), and G. L. c. 93, § 103, regardless of the type of handicap underlying the workplace misconduct, we affirm the grant of summary judgment.4

1. Factual background. We recount the facts in their light [660]*660most favorable to Mammone. See, e.g., Joslyn v. Chang, 445 Mass. 344, 345 (2005); Augat, Inc. v. Liberty Mut. Ins. Co., 410 Mass 117, 120 (1991), citing Mass. R. Civ. P. 56 (c), 365 Mass. 824 (1974). Mammone worked as a staff assistant at the university’s Peabody Museum (museum) from January, 1996, until his termination on March 7, 2003.5 He was usually stationed at the museum’s receptionist desk in the main lobby. Among other responsibilities, Mammone was required to direct individual visitors and tour groups to destinations inside the museum, as well as answer any questions such guests might have. In this position, Mammone had significant contact with the public.6

Mammone suffers from bipolar disorder.7 This mental disease manifests itself in occasional periods of mania (of which paranoia, agitation, hyperactivity, and irrationality are symptoms) and occasional periods of depression. Although Mammone was diagnosed with bipolar disorder in 1987, there is no evidence that, previous to the incidents at issue in this case, his mental disease ever negatively affected his ability to perform his workplace duties. Indeed, there is scant evidence that any of Mammone’s supervisors or coworkers knew of Mammone’s health problems before the events in question.8 During the course of his employment, Mammone received both annual salary increases and positive formal reviews from supervisors.

In the middle of August, 2002, Mammone apparently experienced a manic episode. This episode led to workplace [661]*661misconduct that eventually resulted in his termination. On August 18, Mammone established a website to decry what he believed were the low wages the university pays some of its employees.9 On August 20, while on duty at the museum, he began to distribute flyers summarizing and advertising his website. He also engaged coworkers in loud and animated conversations regarding his website and its content. He frequently used his personal laptop computer to access and update his website during his shift. According to his own testimony, Mammone would sing along with, clap to, and dance to protest songs from his website while stationed at the receptionist desk.10 On August 22, Mammone’s supervisor, Michele Piponidis, informed him, both orally and in writing, that he should not use his laptop computer at work. The next day Mammone sent an electronic mail message to Piponidis refusing to follow her instructions. He continued to bring his laptop computer to work, and to use it in the manner described above, until the date of his termination.

Mammone’s manic episode appeared to reach its zenith between August 29 and September 4. On August 29, when he could not find the keys to his house, he began to believe that a conspiracy had formed against him. That night, Mammone stayed at a local YMCA. However, because he believed persons at the YMCA were also involved in the conspiracy, he telephoned the police the next morning. Although Mammone thereafter was brought to a hospital for overnight examination,11 he did not meet the criteria for involuntary civil commitment [662]*662and was thus released at his own insistence on August 31.12 On September 3, subsequent to the Labor Day holiday, Mammone returned to work, his mania only worsening.13 That day, a staff member of the museum’s public programs office explained to Piponidis that Mammone’s “belligerent attitude is not only affecting [the museum’s] staff, but also visitors to the museum.” That night, Mammone was contacted by his union representative, who left him with the impression that Piponidis was seeking to meet with Mammone and a representative of the university’s office of labor and employee relations for the purpose of terminating his employment.

On the morning of September 4, 2002, Mammone arrived at work in brightly colored, traditional East Indian dress and adorned with necklaces, bracelets, and rings.14 While at his desk, he telephoned the police, his mother, his sister, and an attorney with the American Civil Liberties Union (ACLU) and spoke to each person “very loudly.” When Piponidis approached him and asked him to join her in a private conference room, Mammone refused. He dismissively flicked his hand at her, saying, “Psst, get away from me, you’re evil.” Piponidis left the lobby and returned with both Mary Reynolds, the museum’s human resources administrator, and two university police officers.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Snell v. Descoteaux
D. Massachusetts, 2022
Miceli v. JetBlue Airways Corp.
914 F.3d 73 (First Circuit, 2019)
Bowers v. P. Wile's, Inc.
54 N.E.3d 1089 (Massachusetts Supreme Judicial Court, 2016)
Timothy Mayo v. Pcc Structurals
795 F.3d 941 (Ninth Circuit, 2015)
McLaughlin v. City of Lowell
992 N.E.2d 1036 (Massachusetts Appeals Court, 2013)
Scott v. Encore Images, Inc.
955 N.E.2d 319 (Massachusetts Appeals Court, 2011)
Johansson v. Massachusetts Department of Correction
28 Mass. L. Rptr. 191 (Massachusetts Superior Court, 2011)
Mercado v. Manny's T.V. & Appliance, Inc.
928 N.E.2d 979 (Massachusetts Appeals Court, 2010)
Kelly v. Cort Furniture
717 F. Supp. 2d 120 (D. Massachusetts, 2010)
Martins v. University of Massachusetts Medical School
915 N.E.2d 1096 (Massachusetts Appeals Court, 2009)
Boston Housing Authority v. Bridgewaters
898 N.E.2d 848 (Massachusetts Supreme Judicial Court, 2009)
Boston Housing Authority v. Bridgewaters
871 N.E.2d 1107 (Massachusetts Appeals Court, 2007)
Moreau v. Massachusetts Mutual Life Insurance
22 Mass. L. Rptr. 580 (Massachusetts Superior Court, 2007)
Miller v. Cotter
448 Mass. 671 (Massachusetts Supreme Judicial Court, 2007)
Carleton v. Commonwealth
858 N.E.2d 258 (Massachusetts Supreme Judicial Court, 2006)

Cite This Page — Counsel Stack

Bluebook (online)
847 N.E.2d 276, 446 Mass. 657, 17 Am. Disabilities Cas. (BNA) 1680, 2006 Mass. LEXIS 202, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mammone-v-president-fellows-of-harvard-college-mass-2006.