Nicholas Stover v. Amazon.com, LLC

CourtCourt of Appeals for the Sixth Circuit
DecidedJanuary 10, 2022
Docket21-5421
StatusUnpublished

This text of Nicholas Stover v. Amazon.com, LLC (Nicholas Stover v. Amazon.com, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nicholas Stover v. Amazon.com, LLC, (6th Cir. 2022).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 22a0020n.06

Case No. 21-5421

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

FILED Jan 10, 2022 NICHOLAS STOVER, ) DEBORAH S. HUNT, Clerk ) Plaintiff-Appellant, ) ) ON APPEAL FROM THE UNITED v. ) STATES DISTRICT COURT FOR ) THE EASTERN DISTRICT OF AMAZON.COM, LLC, AMZN WACS, LLC, ) KENTUCKY and AMAZON.COM, INC., ) ) Defendants-Appellees. ) )

Before: GIBBONS, READLER, and MURPHY, Circuit Judges.

CHAD A. READLER, Circuit Judge. For roughly a year, Amazon employed Nicholas

Stover as a call center customer service representative. After numerous incidents, the company

terminated Stover’s employment. Stover, who has a chronic inflammatory bowel disease known

as Crohn’s disease, believed that his relationship with the company soured because of this

condition. So he sued various Amazon affiliates and subsidiaries (for simplicity, we refer to them

collectively as Amazon), alleging that the company violated the Americans with Disabilities Act

(ADA) and the Kentucky Civil Rights Act (KCRA). The district court granted summary judgment

for Amazon. Because the record amply supports the summary judgment grant, we affirm. Case No. 21-5421, Stover v. Amazon.com, et al.

I.

Nicholas Stover joined one of Amazon’s Kentucky-based call centers as a seasonal

customer service representative. The position required Stover to troubleshoot with Amazon

customers over the phone, duties Amazon tracked by requiring its employees to maintain an “aux”

status. That status would reflect a representative’s current activity, such as being on a call,

attending a meeting, or going on break. With respect to the latter activity, Amazon policy afforded

Stover various types of time off and required that, when he took a break, he needed to log it via

his aux status.

Eleven days into his new job, Stover disclosed to an Amazon human resources associate

that he had a “chronic illness” that required him to “frequently visit the restroom” without notice.

As part of that disclosure, Stover asked whether he could have “additional break time to . . . visit

the restroom, as needed.” Viewing Stover’s inquiry as a possible ADA accommodations request,

Amazon gave Stover various forms to complete to allow Amazon’s Leave of Absence

Accommodations (LOAA) team to obtain necessary information (such as medical confirmation

from Stover’s physician) to resolve the request. When Amazon did not hear back from Stover, it

administratively closed his case, with the understanding that Stover could reopen his request by

providing the needed information.

After several months as a seasonal employee, Stover was hired on a non-temporary basis

and later assigned to the “Search and Rescue Team,” which handles difficult, unresolved calls from

customers. Around that same time, Stover visited his gastroenterologist and subsequently opted

to reopen his accommodations inquiry with Amazon. Amazon provided Stover with copies of the

needed paperwork, which Stover eventually completed. In one of the completed forms, Stover

disclosed that he had a gastrointestinal issue that “require[d] more breaks for bathroom use” and

2 Case No. 21-5421, Stover v. Amazon.com, et al.

necessitated him “miss[ing] work or tak[ing] time off” to attend to his condition. Stover’s

gastroenterologist submitted additional information. In language that he would later describe as

open to interpretation, the gastroenterologist indicated that Stover needed (as an accommodation)

to have a bathroom facility “readily available” to him.

Uncertain as to the exact nature of Stover’s request, an LOAA representative asked Stover

for further clarification. Stover specified that his work hours should be reduced from 40 to 32

hours per week, and that he needed the ability to “use the restroom whenever he has an episode.”

The LOAA representative asked Stover to provide supporting documentation from his health care

provider. But Stover did not do so, even after LOAA followed up on its earlier request. So LOAA

again administratively closed Stover’s request for an accommodation until it received more

specific information. Fed up with being “told no” on “multiple occasions,” Stover decided he

“was done” with seeking accommodations.

Stover’s tenure took a turn for the worse with the arrival of his new boss, Michelle Nemeth.

Stover felt that he and his new supervisor had a “personal” conflict, with Nemeth maintaining an

“overall malaise” toward him. Nemeth’s view of Stover, on the other hand, seemingly was shaped

by Stover’s missteps in his customer service role. Stover received some of the poorest customer

response ratings amongst his colleagues, resulting in Nemeth warning him in writing about his

performance. Stover refused to sign the written warning. But he did sign his name to an email

about corporate organizational changes that he sent to Nemeth shortly after the warning. And he

did not mince words. He warned Nemeth that he was “pissed” about how the company was treating

its “most influential employee,” and that she was about to “find [her]self fac[ing] . . . a shit storm

that [he would] funnel larger and larger.”

3 Case No. 21-5421, Stover v. Amazon.com, et al.

That brewing storm, not surprisingly, did little to resolve Stover’s performance issues.

Nemeth discovered that Stover had been confrontational to customers even to the point of hanging

up on them, resulting in another written warning. A few weeks later, Nemeth emailed Stover

asking him to “be mindful of [his] aux times,” after discovering he was repeatedly taking excess

break and personal time. Stover blamed the issue on a bout of food poisoning. A few weeks after

that, Nemeth warned Stover that he had missed more customer calls than anyone on her team.

Stover blamed “system issues” with his computer, which Nemeth tried to resolve by replacing

Stover’s machine. Not long thereafter, Nemeth formally counseled Stover about his excessive

breaks. Stover attributed the issue to his Crohn’s disease, prompting Nemeth to suggest that he

make an accommodations request with human resources. Stover, however, expressed no interest

in doing so.

As these problems mounted, Stover emailed Nemeth to fault his computer “system” for

incorrectly logging his break times. As she dug into the issue, Nemeth discovered a pattern of

Stover switching his aux status to a setting that would functionally route calls received at the end

of his shift to others. Stover admitted to the practice and signed a form acknowledging as much.

(Stover would later testify that he was “[f]or the most part” “helping other employees” during the

times in question, but he never directly disputes his contemporaneous admission to Nemeth.)

Nemeth viewed Stover’s behavior as “egregious.” Fed up, Nemeth, in tandem with other Amazon

managers, opted to terminate Stover’s employment.

Stover eventually sued Amazon for various ADA and KCRA violations. The essence of

his complaint was that Amazon refused to allow Stover to deviate from the company’s “draconian”

break time policy, despite knowing about Stover’s gastrointestinal condition, ultimately resulting

in Stover’s termination. Stover alleged both reasonable accommodation and wrongful termination

4 Case No. 21-5421, Stover v. Amazon.com, et al.

claims under the ADA and the KCRA. Following discovery, Amazon moved for summary

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