ANDREA J. MOSBY-MEACHEM v. MEMPHIS LIGHT, GAS & WATER DIVISION - Articles

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Posted by: Landry Butler on Feb 21, 2018

Court: 6th Circuit Court (Published Opinions)

Attorneys 1:

ARGUED: Michael D. Tauer, GLANKLER BROWN, PLLC, Memphis, Tennessee, for Appellant. Adam W. Hansen, APOLLO LAW LLC, Minneapolis, Minnesota, for Appellee.

Attorneys 2:

ON BRIEF: Michael D. Tauer, Saul C. Belz, Miska L. Shaw, GLANKLER BROWN, PLLC, Memphis, Tennessee, for Appellant. Adam W. Hansen, APOLLO LAW LLC, Minneapolis, Minnesota, William B. Ryan, Janelle Osowski, DONATI LAW FIRM LLP, Memphis, Tennessee, for Appellee.

Judge(s): GIBBONS, GUY, and COOK, Circuit Judges.

Court Appealed: Appeal from the United States District Court for the Western District of Tennessee at Memphis.

JULIA SMITH GIBBONS, Circuit Judge. Andrea Mosby-Meachem, an in-house attorney for Memphis Light, Gas & Water Division, was denied a request to work from home for ten weeks while she was on bedrest due to complications from pregnancy. Following trial, a jury found in favor of Mosby-Meachem on her claim for disability discrimination and awarded her compensatory damages. The district court also granted Mosby-Meachem’s motion for equitable relief and awarded her backpay for the period in which MLG&W did not permit her to telework. MLG&W moved for judgment as a matter of law or, in the alternative, a new trial, asserting that the evidence produced at trial and binding Sixth Circuit precedent precluded any reasonable jury from determining that Mosby-Meachem was a qualified individual while on bedrest because in- person attendance was an essential function of her job. The district court denied the motion and MLG&W appealed both the denial of its motion and the award of equitable relief. Because Mosby-Meachem produced sufficient evidence at trial for a reasonable jury to conclude that in- person attendance was not an essential function of her job for the 10-week period in which she requested to telework and the Sixth Circuit precedent relied upon by MLG&W is materially distinguishable from the facts of this case, we affirm the orders of the district court.