PHILADELPHIA – A panel of judges from the U.S. Court of Appeals for the Third Circuit has affirmed a trial court decision which found that Carnegie Mellon University did not discriminate against a master’s degree student afflicted with attention deficit hyperactivity disorder, when he failed out of the school’s computer science program.
On March 5, Third Circuit judges L. Felipe Restrepo, Stephanos Bibas and David J. Porter ruled to uphold a decision from the U.S. District Court for the Western District of Pennsylvania, in favor of Carnegie Mellon and against plaintiff Sanchit Jain.
Jain, who has ADHD, was a master’s student in the computer science program at Carnegie Mellon. When he enrolled in 2017, he sought disability accommodations, like flexible due dates for his homework, and the school approved them all.
Even so, Jain floundered in his studies that fall: He missed assigned readings, regularly skipped classes, had trouble working with partners, needed many extensions and had to ask for more accommodations. Over the course of the semester, Carnegie Mellon and his professors obliged these requests.
According to Jain, the problem was not his ADHD – but instead, an unrelated sleep disorder. He had been diagnosed with this problem even before he enrolled, but claims it got worse during the semester and started interfering with his coursework.
“Still, he told no one at Carnegie Mellon about his sleep disorder until Dec. 15, 2017. And when at last he emailed the disability office about it, he did not ask for help. Instead, he wrote that “even if there are [accommodations available for it], I’d not seek them,” Bibas said.
“By finals period, Jain had dropped two of his five classes and gotten the lowest passing grade in a third. Worse, he was about to fail the remaining two, Distributed Systems and Computer Networks. He tried three ways to keep those failing grades off his transcript.”
Jain first asked for “incompletes,” or uncommon placeholder grades that would let him finish those classes in the spring, a make-up exam or the chance to retroactively drop the classes. All of these requests were ultimately denied.
“Jain then sued under the Americans with Disabilities Act (ADA) and Rehabilitation Act. He claims that he failed those two classes only because Carnegie Mellon discriminated against him based on his ADHD accommodations. He makes no claim that it was biased against him because of his sleep disorder, nor that Carnegie Mellon denied him any ADHD accommodations,” Bibas stated.
“Instead, his theory is that Carnegie Mellon was annoyed by his constant requests for ADHD accommodations. So though it granted those requests, it later punished him by refusing to grant him the incompletes, makeup test, and retroactive drops. He alleges that Carnegie Mellon would have given him those breaks if he had not already asked for ADHD accommodations.”
After discovery, the District Court granted summary judgment for Carnegie Mellon. Under both statutes, Jain had to prove that he was disabled, or that because his disability, he was qualified for Carnegie Mellon’s program and that Carnegie Mellon dismissed him because of his disability.
However, the court found both that Jain was not qualified and that he was not dismissed because of his ADHD accommodations, leading Jain to appeal to the Third Circuit.
Bibas opined that Carnegie Mellon denied Jain’s requests because “they were so late and vague that it did not even know that he had a problem until the end of the semester”, as opposed to his professors wanting to punish him.
“Jain claims that his professors denied him incompletes, a makeup test and drops to punish him for requesting ADHD accommodations. No reasonable jury could agree,” Bibas said.
According to Bibas, Jain’s interpretation that Carnegie Mellon and its professors gave him failing grades out of bias was “unreasonable.”
“Jain now says that he asked for an incomplete because of his sleep disorder, he never explained that at the time. During the semester, he told Prof. [Srinivasan] Seshan only that Carnegie Mellon had granted him accommodations for an undisclosed disability. Prof. Seshan not only honored those accommodations, but also gave him others, like extra time to study for his midterm exam. So when Jain asked for an incomplete because of ‘some health issues,’ Prof. Seshan had no way to know that Jain meant a new, separate sleep disorder,” Bibas said.
“And Prof. Seshan was willing to give Jain an incomplete – as long as the disability office approved. But it did not. Only then did Prof. Seshan mention Jain’s previous accommodations. In context, he meant only that after all the leeway he had already given Jain, he could not grant another accommodation that the disability office had recommended not giving. So a jury could not reasonably think that Prof. Seshan acted out of anti-disability bias.”
Besides pointing out that Jain did not request a make-up test and was ineligible for a retroactive drop of his class, Bibas additionally explained that in the Court’s view, Carnegie Mellon did not demonstrate bias against Jain.
“Jain points to Carnegie Mellon’s dismissal, which noted his ‘extensive and recurring demands on course instructors to grant extensions, special consideration, and forgiveness.’ He reads this sentence as penalizing him for his accommodations. But the rest of the letter clarifies that Carnegie Mellon dismissed him for his bad grades, not his ADHD. Plus, the quotation is ambiguous. It could refer to his many requests for accommodations not tied to his documented ADHD, like incompletes, the makeup exam and drops. No reasonable jury could conclude, based on this one sentence, that Carnegie Mellon was biased,” Bibas said.
“Jain points out that his credentials were strong enough to gain admission to Carnegie Mellon. It was odd, he says, that just a semester later Carnegie Mellon changed its mind and found him unqualified. But that was not odd. The qualifications to enter a program differ from those to stay in it. Jain lacked the grades to stay enrolled.”
Bibas concluded by upholding the trial court’s granting of summary judgment.
“Jain’s frustration is understandable. But Carnegie Mellon is not to blame. Jain never told its faculty or staff about his sleep disorder until after his difficult semester. By then, it was too late to help him. He failed out because of his own delay, not Carnegie Mellon’s bias. No jury could reasonably find otherwise. So we will affirm the District Court’s grant of summary judgment for Carnegie Mellon.”
U.S. Court of Appeals for the Third Circuit case 20-1637
U.S. District Court for the Western District of Pennsylvania case 2:18-cv-01163
From the Pennsylvania Record: Reach Courts Reporter Nicholas Malfitano at nick.malfitano@therecordinc.com