September 6, 2002
Disability Compliance Bulletin
SECTION: Vol. 24, No. 4
Case name: Langsford v. Yale Univ. Sch. of Medicine, 24 NDLR 98 (2nd Cir. 2002).
Ruling: In an unpublished opinion, the 2nd U.S. Circuit Court of Appeals held that the statute of limitations period for a schoolteacher to file a timely charge of disability discrimination began to accrue after she received a notice of termination letter from the university.
What it means: When a worker is given clear and definite notice of her future termination via written letter, the limitations period for filing a Title I claim against the employer begins to run on the day the worker receives the letter. The worker then has only 300 days from the date she is notified about her pending termination in which to file a disability discrimination charge with the proper administrative agency. Summary: Medical doctor Carol Langsford alleged that Yale University School of Medicine and Yale-New Haven Hospital Corp. violated the ADA by failing to accommodate her disability and terminating her from her employment because of her disability, a chronic illness similar to multiple sclerosis. As a part of her residency, Langsford was employed as a "house officer" at a local teaching hospital.
During her first year of employment, she missed between 28 and 42 days of work due to her illness. Despite efforts to correct her unsatisfactory performance on the job, her illness worsened and her absenteeism increased.
After Langsford asked to take a medical leave, Yale sent her a letter
advising her that her employment would be terminated. Langsford filed a
discrimination charge with the Indiana Civil Rights Commission 302 days
after she received Yale's letter regarding her termination. Langsford failed
to file a timely discrimination charge. The limitations period began to
accrue when Langsford received the letter from Yale that provided her with
clear and definite notice of her termination.
© Copyright 2002 LRP Publications