Manuella Reed, an employee of LePage Bakeries, Inc., suffered from bipolar disorder. On March 13, 1995, she had a fight with a co-worker about the muffin bagger. This incident was followed by a five-day stay in the hospital. On her return, Reed requested accommodation under the Americans With Disabilities Act (ADA) for her disorder. LePage agreed to accommodate Reed by allowing her to walk away from stressful situations.

Last Chance

On June 1, 1996, Reed had a meeting with Cindi Haven, the company’s Human Resource Director, regarding her new shift assignment. But Reed didn’t want the new shift. She began cursing and went into a rage when Haven wouldn’t give her the shift she wanted.

When Reed began to leave the room, Haven told her that she could not begin working that day if she walked out the door. Reed asked if she was being fired and was told no. Reed then began cursing again. Haven called for help and had Reed escorted out of the office.

LePage decided to fire Reed after this incident. Reed brought suit, claiming LePage violated the (ADA) when Haven prevented her from leaving the room during the meeting. She argued that the ADA permitted her to walk away from her supervisors when she felt a rage coming on. LePage filed for summary judgment claiming such an accommodation was unreasonable.

In evaluating the motion, the US District Court noted that the ADA requires employers to make reasonable accommodations to the known physical and mental limitations of an otherwise qualified individual with disabilities. The court concluded that the employee has the burden of putting forward evidence demonstrating that her proposed accommodation exists and is reasonable.

Walking Out on Supervisors Unreasonable

In Reed’s case, the court found that LePage had agreed to allow her to walk away from stressful situations involving co-workers but had not allowed her to walk away from her supervisors. Reed failed to demonstrate that allowing her to walk away from supervisors would be reasonable. The court also noted that such an accommodation would raise a host of questions concerning the efficient operation of the workplace as well as worker safety.

Therefore, Reed failed to meet her burden to show the proposed accommodation was reasonable. Summary judgment motion granted.