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Knuppel v. Texas Health and Human Services

United States District Court, W.D. Texas, Waco Division

October 30, 2019

HAYLIE BROCK KNUPPEL, Plaintiff,
v.
TEXAS HEALTH AND HUMAN SERVICES, Defendant.

          ORDER GRANTING DEFENDANT TEXAS HEALTH AND HUMAN SERVICES COMMISSION'S MOTION FOR SUMMARY JUDGMENT

          ALAN D. ALBRIGHT UNITED STATES DISTRICT JUDGE

         Before the Court is Defendant Texas Health and Human Services Commission's Motion for Summary Judgment. ECF No. 34. The Court considered the Motion, Plaintiff Haylie Brock Knuppel's Response (ECF No. 38), and Defendant's Reply (ECF No. 39). For the following reasons, the Motion is GRANTED.

         I. BACKGROUND

         Plaintiff Haylie Brock Knuppel (“Knuppel”) was diagnosed with epilepsy in 2011. In January 2016, Waco Center for Youth (“WCY”) hired her as a Psychiatric Nursing Assistant I (“PNA I”). WCY is a facility within the Texas Health and Human Services Commission (“Defendant” or “HHSC”), which is the named defendant in this case.

         WCY is a psychiatric treatment facility that serves teenagers with severe emotional difficulties or behavioral disorders. As a PNA I, Knuppel was assigned to monitor two or three patients in their daily afterschool activities. Among other things, she was expected to be prepared to do the following:

• Initiate and perform physical holds (restraints) of combative patients for up to 15 minutes;
• Help place combative patients into a restraint chair;
• Be left alone for hours to monitor an assaultive or self-injurious patient who is under doctor's order for special observations, and initiate restraint if needed;
• Intervene with combative or aggressive people;
• Perform CPR;
• Participate in strenuous physical training for Prevention or Management of Aggressive Behavior; and
• Perform job functions in an often loud and chaotic environment.

         Motion at 5 (“MSJ at ”) (citing Appx. 6-7 “Return to Work Letter”). These tasks are critically important to WCY in creating a safe environment given the potentially dangerous tendencies of some of the facility's patients who are suicidal or aggressive. Defendant reports that seventeen different staff members suffered physical injuries on the job at the hands of patients in the last two fiscal years. MSJ at 2 (citing Appx. 36 ¶ 5).

         Knuppel informed WCY that she was epileptic when she volunteered at the facility after suffering a seizure there. Response at 2 (citing Declaration of Haylie Brock Knuppel at ¶ 4 (“Knuppel Decl. at __”)). She reiterated her diagnosis when she was hired in early January 2016. Id. Critically, she confirmed at the time she commenced this position that her seizures were under control and that she had not had an epileptic seizure in the past eighteen months. MSJ at 4 (citing Deposition of Haylie Brock Knuppel at 80:5-13 (“Knuppel Depo. at __”)). WCY treats all of its new hires uniformly, so Knuppel's employment began with a six-month probationary period. Knuppel suffered three seizures during that time.

         Knuppel's first seizure occurred approximately only three days after she was hired. MSJ at 4; Knuppel Decl. at ¶ 5.WCY placed her on paid emergency leave and required her to get medical clearance from a licensed physician before she would be allowed to return to work. MSJ at 4; Knuppel Decl. at ¶ 5. WCY gave Knuppel a list of the essential functions of her position to inform the doctor who would perform her assessment. MSJ at 4. WCY also provided Knuppel with paperwork to request a reasonable accommodation. MSJ at 5. Knuppel presented a physician's note indicating she could return to work with three restrictions: she could not drive, work in high places, or use dangerous equipment. Knuppel Decl. at ¶ 5. Working in high places or with dangerous equipment were not part of her position, and HHSC accepted the condition that Knuppel would not be permitted to drive. It is undisputed that Knuppel did not return the reasonable accommodation paperwork or otherwise request an accommodation.

         Knuppel's next seizure occurred in May 2016. Knuppel Decl. at ¶ 6. Knuppel's third seizure occurred only about a month later. Knuppel Decl. at ¶ 7. On June 29, 2016, before the probationary period ended, HHSC terminated Knuppel's employment. Knuppel Decl. at ΒΆ 9. Knuppel alleges that in doing so, HHSC unlawfully fired her solely because of her epilepsy in violation of the Rehabilitation Act. HHSC responds that it legally terminated Knuppel because she could not perform the essential functions of her ...


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