Susan L. Hoskins v. Oakland County Sheriff's Department, and the County of Oakland

227 F.3d 719, 2000 U.S. App. LEXIS 18276, 79 Empl. Prac. Dec. (CCH) 40,247, 2000 WL 1043238
CourtCourt of Appeals for the Sixth Circuit
DecidedJuly 31, 2000
Docket99-1491
StatusPublished
Cited by139 cases

This text of 227 F.3d 719 (Susan L. Hoskins v. Oakland County Sheriff's Department, and the County of Oakland) 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.

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Susan L. Hoskins v. Oakland County Sheriff's Department, and the County of Oakland, 227 F.3d 719, 2000 U.S. App. LEXIS 18276, 79 Empl. Prac. Dec. (CCH) 40,247, 2000 WL 1043238 (6th Cir. 2000).

Opinion

OPINION

MOORE, Circuit Judge.

Plaintiff-appellant Susan L. Hoskins, who was a deputy with the Oakland County Sheriffs Department, was fired after she suffered an injury that rendered her unable to restrain inmates. She brought suit against the Sheriffs Department and the County of Oakland (hereinafter referred to collectively as “defendants”), asserting claims under both the Americans with Disabilities Act and Title VII. The district court granted summary judgment to the defendants, and for the following reasons we AFFIRM.

I. BACKGROUND

Susan Hoskins worked for the Oakland County Sheriffs Department (“OCSD”) from 1979 until her termination in 1997. She began her career as a dispatcher at the Oakland County Jail. In 1982, Hoskins successfully tested for the position of deputy sheriff, level one (“deputy one”). Hos-kins’s original placement as a deputy one was in the women’s division at the Oakland County Jail. In 1987, Hoskins was assigned to Oakland County Circuit Court detention, where her duties included transporting prisoners from the jail to detention. From 1993 until her termination in 1997, Hoskins was assigned to the Novi District Court, a position that also involved the transportation of inmates. Hoskins’s positions at both the circuit and district courts involved daily contact with prisoners and the potential for physical confrontation.

On August 25, 1996, Hoskins suffered severe non-work-related injuries when a horse fell on her. Hoskins’s primary care physician, Dr. E. Patrick Mitchell, indicated that Hoskins’s injuries included a “non-displaced fracture of the inferior and superior pubic ramus on the left and fractured bilateral clavicles.” Joint Appendix (“J.A.”) at 122 (Mitchell Letter). As a result of these multiple injuries, Hoskins was hospitalized for two and a half weeks and underwent a recuperation period of a year and a half. Hoskins was treated by two different doctors and obtained letters restricting her activity from both. On July 11, 1997, Dr. William Bria, a pulmonary specialist, wrote a letter stating that Hoskins “is able to return to work, however, she should not be lifting or engaging in *723 any activity that would jar her chest, such as shooting a shotgun or getting into a situation in which she could get hit in the chest.” J.A. at 121 (Bria Letter). On July 18, Dr. Mitchell attached a disability certificate to Dr. Bria’s letter; the certificate indicated that Hoskins was restricted to light work duties that did not impact her anterior chest or shoulders. Dr. Mitchell also wrote a letter on September 29, 1997 that stated:

[Hoskins] has restrictions of no lifting, pushing or pulling over 20 pounds, no use of shotgun and no restraining of inmates. She still experiences pain and decreased range of motion. She has severe limitation of her functional capacity and needs a sedentary position. Her motivation and rehabilitation potential is excellent. Her prognosis is guarded.
I do not believe that Susan will ever be able to resume full duty as a Deputy with Oakland County Sheriffs Department. She will probably need permanent restrictions of certain activities which would be considered duties of a Deputy Sheriff.

J.A. at 122 (Mitchell Letter).

After receiving Dr. Bria’s July 11 letter with the attached disability certificate, Hoskins took them to Carol VanLeuven, an employee records specialist for the County. Although Hoskins expressed a desire to return to work, VanLeuven told her that she could not because no light duty positions were available. The County then conducted a pre-termination hearing on November 7, 1997. At the hearing, Major Thomas Quisenberry, the Chief of Staff at OCSD, indicated that Hoskins was being terminated because her work restrictions were incompatible with the duties of a deputy one. Hoskins was asked if she was interested in a job as a dispatcher or a booking clerk — jobs that did not require inmate contact but that also involved a significant pay cut — and she replied that she was not interested. Hoskins stated, “Basically I’d rather just be a Deputy.” J.A. at 130. After the hearing, the hearing officer issued a decision affirming Hoskins’s termination.

On June 16, 1998, Hoskins filed suit in the United States District Court for the Eastern District of Michigan, asserting claims under both the Americans with Disabilities Act (“ADA”), 42 U.S.C. § 12101 et seq., and Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq. On March 26, 1999, the district court granted the defendants’ motion for summary judgment. The district court dismissed Hos-kins’s ADA claim on the basis that she failed to establish that she had a disability within the meaning of the Act. Alternatively, the district court reasoned that Hoskins had not satisfied the second element of her prima facie case because she had not established that she was qualified to perform the essential functions of the job with reasonable accommodation. Hoskins also brought a disparate treatment claim under Title VII, alleging that OCSD had provided male deputies the opportunity to work in light duty deputy positions following disabling injuries. The district court dismissed this claim on the basis that Hoskins had not established a prima facie case of gender discrimination. Hoskins timely appealed the district court’s judgment.

II. ANALYSIS

We review de novo a district court’s grant of summary judgment. See Ercegovich v. Goodyear Tire & Rubber Co., 154 F.3d 344, 349 (6th Cir.1998). Summary judgment is proper only when there is no dispute as to a material question of fact and one party is entitled to a judgment as a matter of law. See Fed.R.Civ.P. 56(c). Viewing all facts and inferences drawn therefrom in the light most favorable to the nonmovant, we must determine whether the evidence presented is such that a reasonable jury could find for that party. See Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587, 106 S.Ct. 1348, 89 L.Ed.2d 538 (1986).

*724 A. ADA Claim

The ADA prohibits covered employers from discriminating “against a qualified individual with a disability because of the disability of such individual in regard to job application procedures, the hiring, advancement, or discharge of employees, employee compensation, job training, and other terms, conditions, and privileges of employment.” 42 U.S.C. § 12112(a).

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227 F.3d 719, 2000 U.S. App. LEXIS 18276, 79 Empl. Prac. Dec. (CCH) 40,247, 2000 WL 1043238, Counsel Stack Legal Research, https://law.counselstack.com/opinion/susan-l-hoskins-v-oakland-county-sheriffs-department-and-the-county-of-ca6-2000.