Maria Smith v. Mich. Bell Telephone Co.

── Maria Smith v. Mich. Bell Telephone Co. ── Court: Court of Appeals for the Sixth Circuit Date: June 04, 2026 Category: General NOT RECOMMENDED FOR PUBLICATION File Name: 26a0253n.06 No. 25-1946 UNITED STATES COURT OF APPEALS FILED FOR THE SIXTH CIRCUIT Jun 04, 2026 KELLY L. STEPHENS, Clerk ) ) MARIA SMITH, ) ON APPEAL FROM THE Plaintiff–Appellant, ) UNITED STATES DISTRICT ) COURT FOR THE EASTERN v. ) DISTRICT OF MICHIGAN ) MICHIGAN BELL TELEPHONE COMPANY, ) OPINION Defendant–Appellee. ) ) Before: STRANCH, BUSH, and BLOOMEKATZ, Circuit Judges. JOHN K. BUSH, Circuit Judge. Maria Smith sued her former employer, Michigan Bell Telephone Company, bringing several claims under the Americans with Disabilities Act (ADA). Michigan Bell moved for summary judgment, and the district court granted the motion. We AFFIRM. I. Smith worked for Michigan Bell and had “an extensive leave of absence history.” R. 34- 3, Peck Decl., PageID 630. During her time with Michigan Bell, Smith was subject to a progressive discipline policy pursuant to a collective bargaining agreement. In May 2021, Michigan Bell approved Smith’s request while pregnant to work from home through her delivery date (approximately the end of August 2021) as an ADA accommodation. As part of her request, Smith included her physician’s recommendation that she limit her commute time to less than four hours and work from home to decrease her risk of exposure to the COVID- No. 25-1946, Smith v. Mich. Bell Telephone Co. 19 virus. Her physician noted that “[by] being pregnant[,] she is more at risk and considered immune compromised” and that “all pregnant patients are at risk for blood clots.” R. 34-4, Ex. A- 1 to Pratt Decl., PageID 734. But Smith experienced difficulties receiving her work equipment— she was forced to physically go to the office once to get her computer, some cords had to be mailed at a later date, and she struggled to log into her computer. While Smith was in the office retrieving her equipment, a Michigan Bell attendance manager conducted an “Attendance Action Plan” meeting with Smith to discuss her absences. During that meeting, Smith was issued an “attendance counseling,” the first step in Michigan Bell’s progressive discipline process, for unapproved absences in 2020 (August 12 through December 31) and 2021 (May 25 through June 23). Smith did not receive any further discipline. Two years later, in February 2023, Smith started a full-time job with the City of Kalamazoo but did not inform Michigan Bell until she voluntarily resigned from her position at Michigan Bell in April 2023. As is relevant here, Smith sued Michigan Bell for discrimination, failure to accommodate, and retaliation under the ADA. The district court granted summary judgment to Michigan Bell, concluding that Smith had not established a prima facie case of disability discrimination because she failed to provide sufficient evidence that she was disabled and that she suffered an adverse employment action. For similar reasons, the district court also granted summary judgment to Michigan Bell on Smith’s failure to accommodate and retaliation claims. Smith timely appealed.