Labor & Employment Law Daily Wrap Up, WORTH NOTING—Recent developments involving disability discrimination, (Sep 3, 2026)

By WK Editorial Staff

A roundup of recent decisions involving disability discrimination claims of interest to the labor and employment law community.

S.D. Fla.: Employee was denied medical leave requests, suffered medical emergency. An employee with sickle cell anemia sued her employer under the ADA, FMLA, and Florida Civil Rights Act (FCRA), and for failure to accommodate, interference, and retaliation. She alleged that the employer denied protected medical leave requests and required “repeated and unnecessary medical documentation.” She alleged that the employer refused leave for a follow up appointment after she suffered a medical emergency. She alleged that she subsequently suffered a sickle-cell crisis after attending work instead of the appointment. She also alleged that employer’s HR representatives repeatedly contacted her during a hospitalization and that she resigned after continued interference. The employer moved to dismiss. The district court granted the motion in part and denied it in part. The court held that the employee exhausted her administrative remedies. The court dismissed the ADA and FCRA failure to accommodate claims because the complaint did not allege facts showing she could perform her position’s essential functions with or without accommodation. The court held that the employee adequately alleged a disability based on her sickle cell anemia. The court allowed the FMLA interference claim to proceed because the complaint plausibly alleged FMLA eligibility and denial of benefits. The court also allowed the FMLA and disability retaliation claims to proceed because the complaint plausibly alleged protected activity and a causal connection to adverse actions (Vaccianna v. University of Miami, No. 25-24636-CIV-MORENO (S.D. Fla. Aug. 24, 2026)).

E.D. Mich.: Reconsideration denied because employee was unable to work, not entitled to two-year leave. An employee sued his employer and supervisor alleging disability discrimination and retaliation under the ADA, retaliation under the Whistleblowers’ Protection Act and Workers’ Disability Compensation Act, and hostile work environment under Michigan’s Persons with Disabilities Civil Rights Act (PWDCRA), after his termination while on medical leave following an automobile accident at work. The employer and supervisor moved for summary judgment, which was granted. The employee moved for reconsideration. The court denied the motion. It held that the employee could not establish a prima facie ADA discrimination claim, noting that he was not medically cleared to return to work when he was terminated. The employee argued that a collective bargaining agreement entitled him to a two-year leave. The court held that the agreement did not show that extended leave was required under the ADA. The court further held that the motion for reconsideration could not be used to raise new legal arguments (Haack v. Lapeer County Road Commission , No. 4:23-cv-12273 (E.D. Mich. Aug. 26, 2026)).

E.D.N.C.: Store manager’s termination closely followed approval for long-term disability leave. A longtime store manager became severely ill and stopped working in February 2024. The employer denied FMLA leave because the employee lacked the required hours. The employee received short-term disability benefits and later obtained long-term disability benefits. The employer terminated him in June 2024 while he remained on approved disability leave. The employee sued the employer and district manager, alleging ADA discrimination and retaliation, Title VII race discrimination and three state-law claims for wrongful discharge, intentional infliction of emotional distress (IIED), and breach of implied contract. The employer and district manager moved to dismiss for failure to state a claim. The court allowed the ADA claims because termination occurred less than one month after approval of long-term disability leave. The wrongful discharge and implied contract claims also survived. The court dismissed the Title VII claim because the EEOC charge alleged only disability discrimination. The IIED claim failed because the alleged termination was not “extreme and outrageous” per North Carolina law (Herring v. Family Dollar Stores of North Carolina, LLC , No. 4:25-CV-77-BO-RN (E.D.N.C. Aug. 25, 2026)).

D.S.C.: Employee ‘reached an agreement’ to arbitrate disputes during onboarding. A technician working for an appliance company was terminated in March 2025, and sued the company alleging discrimination and retaliation under the ADA, FMLA, Title VII, and the Rehabilitation Act, and state law claims. The employee had signed an arbitration agreement during onboarding. His employment ended slightly more than two months later. The employer moved to dismiss and compel arbitration. The magistrate issued a report recommending that the court grant the motion to compel arbitration. The court recommitted the matter to the magistrate, noting that the issue of contract formation needed to be addressed. The employee sought additional onboarding documents concerning contract formation. After having supplied documentation, the employer moved for summary judgment on that issue. The court granted the employer’s motions for summary judgment and compelled arbitration. The employee’s signature established acceptance of the agreement. The employee testified during his deposition that “he had a chance to read over the documents and did so to the best of his ability” and admitted that his failure to understand the arbitration agreement was “basically…no fault of anybody else’s but [his] own.” The court granted summary judgment as to contract formation, and it granted the motion to compel arbitration (Riley v. Samsung Electronics Home Appliances America, LLC , No. 8:25-cv-8398-TMC (D.S.C. Aug. 27, 2026)).

Cases: DisabilityDiscrimination Discrimination Discharge Retaliation Whistleblowers Labor ContractClaims TortClaims EmployeeLeave PublicEmployees StateLawClaims RemediesDamages Arbitration Procedure