Byrne v. Monmouth County Department of Health Care Facilities
Byrne v. Monmouth County Department of Health Care Facilities
Opinion of the Court
OPINION
Mary Beth Byrne appeals from the District Court’s grant of summary judgment in favor of her former employer, Monmouth County Department of Health Care Facilities, and her former supervisors, ll-ene Van Duyne and Robyn Snyder, on her claims arising under the Americans with Disabilities Act, 42 U.S.C. § 12101 et seq., and the New Jersey Law Against Discrimination, N.J.S.A. § 10:5-1 et seq. We exercise plenary review, construing the evidence in the light most favorable to Byrne. Farrell v. Planters Lifesavers Co., 206 F.3d 271, 278 (3d Cir. 2000). We assume the parties’ familiarity with the factual and procedural history, which we describe only as necessary to explain our decision. We will affirm.
As an initial matter, Ms. Byrne’s certification — which she cites as the only source of material factual disputes — fails
Even were we to consider Ms. Byrne’s certification, however, she has not made a prima facie case of failure to accommodate under the statutes.
Accordingly, we will affirm the judgment of the District Court.
. Ms. Byrne has apparently abandoned her discrimination, harassment, and retaliation claims for purposes of this appeal. In any event, we agree with the District Court that she failed to raise a material factual dispute with respect to these theories, as well.
. To the extent Ms. Byrne wanted to be able to leave work frequently without advance notice — -in violation of County policy — so that she could see her doctors, such an accommodation was not requested, and if it had been requested, it would have been unreasonable as a matter of law.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.