Hatchett v. Philander Smith College

HATCHETT V. PHILANDER SMITH COLLEGE

Why did the court not require the college to provide these accommodations for Hatchett?

The court did not require the college to provide the accommodations requested by Hatchett because the job description of Business Manager included holding monthly meetings and attending seminars and would have required Hatchett to confer with parents and students about unpaid tuition and the impact on the student's ability to sit for finals.

According to the instructions from her physician, Hatchett's medical condition precluded some of these essential functions of the position. Specifically, face-to-face meetings are an essential function of the position and the nature of some of the issues involving student financial aid eligibility could very well result in conflict and emotional interactions.

While Hatchett's request for accommodations in the way of a shorter shift could be considered a reasonable accommodation, the court determined that her functional limitations rendered her unqualified for the position. Since the protections available under the ADA require that the plaintiff necessarily be qualified for the position at issue,

Hatchett could not prevail under any ADA claim.

2. Did the fact that Hatchett's initial injury occurred in a work-related setting affect the court's analysis of her legal claims? As a policy matter, should this fact make a difference in the ADA/FMLA analysis?