Energy Harbor Nuclear Corp. reassigned a maintenance supervisor with nearly 30 years of service to 12-hour night shifts. He complained that the schedule was worsening his Type 2 diabetes, specifically that the night shift was "killing" him. Management told him to provide medical documentation if he needed an accommodation. Upon his presentation of a doctor's note, the company moved him to day shift as requested.
Then came the problem. The company audited his outage time entries against objective badge-swipe data from the plant's protected area. The audit revealed discrepancies in 21 of 26 entries, including 10 overstated by more than 30 minutes. Management interviewed him (with a witness present), reviewed security data, escalated the issue to HR, and a separate internal review team conducted its own investigation. The company fired him for falsifying time records.
He sued for disability discrimination, failure to accommodate, and retaliation.
The 6th Circuit affirmed summary judgment across the board.
First, there was no failure to accommodate. The employer was entitled to request medical documentation—and acted promptly upon receipt. The court rejected the employee's attempt to reframe his termination as the accommodation failure itself.
Second, timecard falsification is a legitimate, nondiscriminatory reason for termination. The employee didn't deny the discrepancies existed. He argued they were mistakes or caused by his diabetes. That doesn't matter. Under the honest-belief rule, courts don't second-guess a decision made after a reasonably informed investigation.
Third, his comparator evidence went nowhere. He couldn't show similarly situated employees committed comparable integrity violations and kept their jobs.
Finally, the retaliation claim failed for the same reason: no pretext.
Employers, here are your four key takeaways.
Then came the problem. The company audited his outage time entries against objective badge-swipe data from the plant's protected area. The audit revealed discrepancies in 21 of 26 entries, including 10 overstated by more than 30 minutes. Management interviewed him (with a witness present), reviewed security data, escalated the issue to HR, and a separate internal review team conducted its own investigation. The company fired him for falsifying time records.
He sued for disability discrimination, failure to accommodate, and retaliation.
The 6th Circuit affirmed summary judgment across the board.
First, there was no failure to accommodate. The employer was entitled to request medical documentation—and acted promptly upon receipt. The court rejected the employee's attempt to reframe his termination as the accommodation failure itself.
Second, timecard falsification is a legitimate, nondiscriminatory reason for termination. The employee didn't deny the discrepancies existed. He argued they were mistakes or caused by his diabetes. That doesn't matter. Under the honest-belief rule, courts don't second-guess a decision made after a reasonably informed investigation.
Third, his comparator evidence went nowhere. He couldn't show similarly situated employees committed comparable integrity violations and kept their jobs.
Finally, the retaliation claim failed for the same reason: no pretext.
Employers, here are your four key takeaways.
1.) Document accommodation requests and responses.
2.) Use objective data when investigating misconduct.
3.) Interview, corroborate, and escalate appropriately.
4.) If integrity is the issue, treat it as a bright line.
You can accommodate a disability and still enforce honest timekeeping and other work rules. If you do it correctly, courts will back you up.