Daniel Lonergan v. Gallagher Sharp, LLP

── Daniel Lonergan v. Gallagher Sharp, LLP ── Court: Court of Appeals for the Sixth Circuit Date: May 29, 2026 Category: General NOT RECOMMENDED FOR PUBLICATION File Name: 26a0245n.06 No. 25-3808 UNITED STATES COURT OF APPEALS FILED FOR THE SIXTH CIRCUIT May 29, 2026 KELLY L. STEPHENS, Clerk ) DANIEL LONERGAN, ) Plaintiff-Appellant, ) ON APPEAL FROM THE ) UNITED STATES DISTRICT v. ) COURT FOR THE NORTHERN ) DISTRICT OF OHIO GALLAGHER SHARP, LLP, ) Defendant-Appellee. ) OPINION ) ) Before: BOGGS, CLAY, and GILMAN, Circuit Judges. CLAY, Circuit Judge. In his lawsuit under the Americans with Disabilities Act (the ADA), 42 U.S.C. § 12101 et seq., and Ohio Revised Code § 4112.02, Plaintiff Daniel Lonergan appeals from the district court’s order and judgment granting Defendant Gallagher Sharp, LLP’s, motion for judgment on the pleadings, dismissing Plaintiff’s complaint, and denying Plaintiff’s motion for reconsideration. For the reasons set forth below, we AFFIRM the district court’s order and judgment. I. BACKGROUND A. Factual Background On review of a dismissal pursuant to Federal Rule of Civil Procedure 12(c), “we accept as true all of the factual allegations contained in the complaint.” Engler v. Arnold, 862 F.3d 571, 573 (6th Cir. 2017) (citing Kottmyer v. Maas, 436 F.3d 684, 689 (6th Cir. 2006)). According to his complaint, Plaintiff, a practicing attorney, “struggles with severe Attention Deficit Hyperactivity No. 25-3808, Lonergan v. Gallagher Sharp, LLP Disorder” (ADHD). Compl., R. 1, PageID #2. After graduating from law school in 2020, Plaintiff began working for a law firm in Cleveland, Ohio, but had to leave “to address mental health concerns.” Id. In July 2023, he began working as a litigation associate for Defendant, another law firm based principally in Cleveland. Soon after starting at the firm, Plaintiff found it challenging to record billable hours “in the manner the firm desired.” Id. at PageID #3. Plaintiff informed Defendant of his ADHD diagnosis and requested “modification[s] to job requirements” that Defendant “flatly denied.” Id. at PageID #1. Members of Defendant’s management told Plaintiff “that this was not their problem, and that [Plaintiff] should have figured out how to deal with [his] disability by this point in [his] life.” Id. at PageID #3. Plaintiff “repeatedly approached partners at the firm and suggested accommodations,” and they responded that his “suggestions simply would not work.” Id. The complaint does not specifically describe the accommodations that Plaintiff proposed. According to Plaintiff, Defendant “refused to engage in a good faith discussion concerning possible accommodations.” Id. at PageID #1. In their briefing, the parties subsequently discussed additional details about the accommodations that Plaintiff had proposed to Defendant. For example, Plaintiff had suggested that a legal assistant might identify the projects on which Plaintiff worked each day and Plaintiff would “backfill” the time spent on each of them, that he be assigned only “flat-rate” projects, that a legal assistant could completely record his time on his behalf, or that the firm charge clien