Ferguson v. Univ. Hosp. Health Sys., Inc.

Citations

• 2022 Ohio 3133

Syllabus

Summary judgment Civ.R. 56 meaningful appellate review statement of reasons Ohio Civil Rights Act R.C. Chapter 4112 disability discrimination employment discrimination retaliation failure-to-accommodate discrimination 12-hour shifts. The trial court did not commit reversible error by failing to set forth detailed reasoning in its journal entry granting summary judgment to the defendant. A hospital was entitled to summary judgment on its employee's disability-discrimination, failure-to-accommodate, and retaliation claims where the hospital's reasonable staffing judgment required nurses to work twelve-hour shifts, the employee's doctor restricted the employee from working more than eight hours at a time and the employee and his doctor proposed no alternative accommodation other than working all eight-hour shifts. The employee's requested accommodation would have required the hospital to create a new shift for him, would have required other nurses to pick up the employee's patients for four hours at the end of each of his shifts, and would have negatively affected patient care by increasing the number of patient handoffs between nurses it was therefore not a reasonable accommodation.