Unreported / Non-Citable
Background
Giram Sanchez Figueroa, one of several current and former American Airlines employees pursuing individual claims after the court denied class certification, worked as a Customer Assistance Representative at Dallas Fort Worth International Airport. Sanchez has major depression, PTSD, and generalized anxiety, which sometimes caused physical symptoms and led to unexpected breaks or absences.
Sanchez sought FMLA or medical leave six times but submitted the required medical certification only once, resulting in approval of that request and denial of the other five. The unexcused absences generated points under American’s progressive attendance policy, and American terminated him in June 2024. Sanchez asserted one claim under the Americans with Disabilities Act: that American failed to accommodate his anxiety.
The Court’s Holding
The court granted American’s motion to strike Sanchez’s deposition errata. Sanchez submitted the errata nearly four months after his deposition, outside Federal Rule of Civil Procedure 30(e)’s 30-day period, and offered no compelling basis for an exception. The proposed changes added testimony that could manufacture a factual dispute absent from the original transcript, so the court did not consider them at summary judgment.
The court also granted American summary judgment and dismissed Sanchez’s sole claim with prejudice. Because Sanchez’s limitations and proposed accommodation were not open and obvious, he had to identify his disability, explain its resulting workplace limitations, suggest a reasonable accommodation, and communicate that information to American. The record did not show that he told an appropriate manager or supervisor that anxiety caused a workplace limitation requiring accommodation, submitted medical notes identifying anxiety, or proposed an accommodation. Merely mentioning anxiety while discussing accumulated attendance points—along with other explanations for absences—did not give American the required notice.
Key Takeaways
- When a disability and its workplace effects are not obvious, an ADA plaintiff must specifically communicate the disability, the resulting limitations, and a proposed reasonable accommodation.
- General awareness that an employee has anxiety, without notice of how it limits the employee’s work or what accommodation is needed, does not establish an ADA failure-to-accommodate claim.
- An untimely deposition errata may be stricken when it materially changes testimony and would create a factual dispute not present in the original deposition.
Why It Matters
The decision underscores that notice is a critical element of an ADA accommodation claim, particularly for mental-health conditions whose workplace consequences may not be apparent. Employees need not use specific legal terminology, but they must provide enough information to connect the condition to a work-related limitation and a possible accommodation.
The ruling also cautions litigants that Rule 30(e) is not an open-ended opportunity to supplement deposition testimony after summary-judgment issues become clear. Material changes submitted outside the rule’s deadline may be excluded, leaving the court to evaluate the claim on the original record.