Texas Department of Family and Protective Services v. Carlotta Howard
Carlotta Howard, a Human Services Tech III for the Texas Department of Family and Protective Services, was terminated after a car accident led to severe injuries and medical leave. She exhausted her sick and FMLA leave and was unable to return to full-time work due to medication-induced dizziness and back spasms. Howard sued for disability discrimination and failure to accommodate under the Texas Labor Code. The trial court denied the Department's plea to the jurisdiction. On appeal, the court affirmed in part, finding a fact issue on disability discrimination, but reversed in part, dismissing the failure to accommodate claim because driving, a 75% essential function, could not be performed with the requested part-time accommodation.