The Sixth Circuit Court of Appeals ruled on August 3, 2026, that the City of Detroit did not discriminate against former police officer Dawn Wortham. The court affirmed a lower court's decision to dismiss her claims under the Americans with Disabilities Act (ADA) after a jury found in favor of the City. This ruling impacts Wortham and other employees who may seek accommodations for disabilities in the workplace.
Wortham, who worked as a patrol officer, sustained injuries in a car accident that led to her being placed on restricted duty. After years of limited work, she faced challenges when returning to full duty, including psychological distress. Wortham's case against the City centered on allegations of intentional discrimination and failure to accommodate her disabilities.
The dispute began when Wortham filed a lawsuit against the City of Detroit after her employment was terminated in 2022. She claimed the City discriminated against her based on her disabilities, arguing that her termination was retaliatory due to her complaints about the handling of her accommodation requests. The case was initially filed in the U.S. District Court for the Eastern District of Michigan and later appealed to the Sixth Circuit, where judges Ronald Lee Gilman, Richard Allen Griffin, and Chad A. Readler presided.
In its ruling, the Sixth Circuit upheld the lower court's decisions, stating that the City had legitimate reasons for terminating Wortham's employment. The court noted, "The City made a reasonably informed and considered determination that Wortham should be fired for failing to present the requested medical documentation." The judges emphasized that Wortham's repeated failure to provide necessary medical forms justified the City's actions.
The court also addressed Wortham's arguments regarding her retaliation claim, stating that she had not provided sufficient evidence to demonstrate that her termination was linked to her previous complaints about discrimination. The judges found that the City had valid grounds for her termination, primarily her failure to report for duty and provide updated medical documentation.
Wortham's claims of failure to accommodate and intentional discrimination were also rejected by the jury. The court found that she did not properly request accommodations under the ADA, stating that the City was not obligated to provide accommodations without a formal request and proper medical documentation. The court ruled, "An employer is under no obligation to craft an accommodation for an employee who has never asked for one."
This ruling is significant as it reinforces the need for employees to follow proper procedures when seeking accommodations for disabilities. It highlights the importance of providing necessary documentation and communicating effectively with employers about medical conditions. The court's decision may influence how other employees approach similar cases in the future.
As for what lies ahead, Wortham's options for appeal are limited. The Sixth Circuit's ruling is final unless new evidence emerges or procedural errors are identified that could warrant further review. There are no related cases currently pending that could impact this ruling.