New Jersey Employment Lawyer Blog
Employees in New Jersey have strong legal protection against workplace discrimination, retaliation, and interference with medical leaves. A recent decision in Naranjo v. United Airlines, Inc. reinforces those rights, particularly for workers managing chronic health conditions. The federal court’s opinion allows a former flight attendant’s disability discrimination and Family and Medical Leave Act (FMLA) claims to proceed to trial, rejecting the airline’s motion to dismiss the case.
The Background of the Case
Samantha Naranjo worked as a flight attendant for United Airlines from 1999 until the company fired her in June 2022. During her employment, she was diagnosed with Crohn’s disease—a serious, chronic medical condition that can cause severe digestive flareups. To manage her condition, Ms. Naranjo regularly applied for intermittent medical leaves under the FMLA.
In May 2022, Ms. Naranjo called out of work due to her Crohn’s symptoms. A few days later, she tested positive for COVID-19 and followed the company’s policies for pandemic-related absences. However, despite notifying her supervisors and providing documentation, United still gave her an attendance point for her May 13 absence. Under United’s strict attendance policy, employees who accumulate 30 or more “points” face termination.
By June 6, 2022, Ms. Naranjo had reached the 30-point threshold and United fired her. She filed a lawsuit alleging United violated the Americans with Disabilities Act (ADA), the New Jersey Law Against Discrimination (NJLAD), and the FMLA by discriminating against her because of her disability, failing to accommodate her medical condition, and retaliating against her for seeking a protected medical leave.
United Files for Summary Judgment
United Airlines moved to dismiss the case through a motion for summary judgment, arguing its decision to terminate Ms. Naranjo’s employment was justified. Specifically, it claimed it fired her for excessive unexcused absences, in violation of company policy, rather than because of her disability. United also argued that since “dependability” was an essential function of a flight attendant’s job, allowing intermittent absences for Crohn’s disease was not a reasonable accommodation.
Disability Discrimination and Failure to Accommodate Claims
The court found substantial evidence supporting Ms. Naranjo’s allegations of disability discrimination and failure to accommodate under the ADA and the NJLAD.
United did not dispute that Ms. Naranjo had a disability. Instead, it argued that she was not qualified for her job because she could not meet attendance requirements. The court disagreed, finding that whether “dependability” was truly an essential job function was a factual question that must be decided by a jury.
Ms. Naranjo testified that she informed her supervisors about her Crohn’s disease and requested help managing her absences. Rather than assist her, she alleges one supervisor told her to “do better” and that she “can’t call in anymore.” Further, since most of her attendance points were linked directly to her medical condition, the court determined that a jury could find United discriminated against her by counting disability-related absences against her.
The court also found evidence suggesting United failed to make a good faith effort to accommodate Ms. Naranjo’s disability. She repeatedly asked for assistance and explained her situation, but no one directed her to the appropriate accommodation process or offered her any alternatives.
FMLA Interference and Retaliation
The court also denied United’s motion on Ms. Naranjo’s FMLA claims. She alleged that United interfered with her right to take a medical leave and retaliated against her by terminating her because she sought time off for work that was protected under the Act.
United argued that Ms. Naranjo missed a deadline to submit a medical certification for her May 13 absence. The court found factual disputes about whether her late submission was excused by extenuating circumstances, including her COVID-19 diagnosis and ongoing Crohn’s flareup. The judge also noted that United could have extended the deadline or reconsidered its decision once it received the certification.
These unresolved issues, combined with the timing of her termination just weeks after she sought leave, were enough for the court to let Ms. Naranjo’s case move forward.
What This Decision Means for New Jersey Workers
The ruling in Naranjo v. United Airlines, Inc. serves as an important reminder that employees in New Jersey have the right to take a medical leave and to request reasonable accommodations without fear of losing their jobs. Employers must consider each request individually and cannot use attendance policies to avoid their legal obligations.
For workers with chronic medical conditions, documenting communication with supervisors and maintaining copies of medical certifications can be essential. Courts are willing to look beyond an employer’s stated reasons for termination when there is evidence that disability-related absences or a protected request for a medical leave played a role in its decision.
Speak with a Bergen County Employment Lawyer
If you believe your employer has denied you a reasonable accommodation, interfered with your FMLA rights, or retaliated against you because you requested a medical leave, Rabner Baumgart Ben-Asher & Nirenberg, P.C. can help. Our attorneys have extensive experience handling disability discrimination and retaliation claims under both federal and New Jersey law.
Please call (201) 777-2250 or contact us online to schedule a consultation with a Bergen County employment lawyer who can protect your rights and help you move forward.