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In Carrozza v. Howard County, Maryland, the Fourth Circuit found that the plaintiff was "disabled," but found no violation of the ADA, because even with "reasonable accommodations," she could not "perform the essential functions of her job."
In 1983, Carrozza, who was later diagnosed with manic depression, became a clerk typist for Howard County (County). In 1991, she was transferred to another clerk typist position within the county. Before accepting the new position, Carrozza received a detailed job description which indicated that proficiency in various word processing programs was required for the position. Although she had extra time for training, Carrozza could not perform computer assignments competently. For over a year, the County provided ample training opportunities, but her performance was never close to acceptable. Carrozza's supervisor concluded that her work was "severely deficient compared to the reasonably expected proficiency level."
In addition to her computer problems, Carrozza displayed bizarre and insubordinate behavior. First, she dumped trash on a conference table while her supervisor was conducting a meeting. Second, she was hospitalized under the care of a psychiatrist, for nine days. Third, on several occasions, she was disciplined for insubordinate behavior. In June 1992, the County notified her of its intent to discharge her. At her pre-termination hearing, Carrozza admitted she could not perform the basic tasks of her job. She was told that the County had no vacant clerk typist positions available and was terminated. In response, Carrozza filed a complaint with the EEOC, and then sued in federal court. The district court granted summary judgment to the County and Carrozza appealed.
The Fourth Circuit noted that the ADA prohibits employment discrimination against a "qualified individual with a disability." To recover under the ADA, a plaintiff must show (1) that they are disabled, (2) that they are "qualified," and (3) that the employer's termination constituted unlawful discrimination. The court found that Carrozza's condition was a disability under the ADA. The court also noted that the ADA defines a "qualified person with a disability" as someone with a disability who, with or without reasonable accommodation, can perform the essential functions of the position. The court added that to determine whether Carrozza was "qualified," it must decide (1) whether she could perform the essential functions of the job (i.e. functions that bear more than a marginal relationship to the job at issue), and (2) if not, whether "any reasonable accommodation by the employer would enable her to perform those functions."
The Fourth Circuit noted that Carrozza had severe deficiencies in performing the essential functions of her job, namely working with the computer and maintaining acceptable standards of conduct. The court stated that the fact that her problems may have stemmed in part from her mental health condition did not excuse her failure to perform those essential functions. The court also addressed Carrozza's claim that she could have performed her duties if given reasonable accommodation. The court found that reasonable accommodations do not include steps which require reallocation of "essential job functions" or which are shown to "impose an undue hardship on the employer." The court noted the County's exhaustive efforts to accommodate Carrozza, including extensive training for the computer and counseling and medical leave for her mental condition. Thus, the court affirmed summary judgment for the County.
Carrozza v. Howard County, Maryland, 45 F.3d 425 (4th Cir. 1995).