Here is plaintiff Ivana Hidalgo’s disability discrimination complaint, captioned Hidalgo v. B&B Hospitality Group LLC (SDNY 13-cv-6402 filed 9/12/13) against B&B Hospitality Group LLC and others.
Plaintiff claims that defendants violated the Americans with Disabilities Act and the New York State Human Rights Law by failing to reasonably accommodate her disability – an inequality in the lengths of her legs following surgery after a car accident – and then firing her.
Specifically, she alleges that defendants failed to accommodate her by refusing her repeated requests for a stool (even after receiving a doctor’s note suggesting that this would facilitate healing); that she was forced to engage in “bending, heavy lifting, pushing, and walking on the concrete floors” which exacerbated her disability; and that defendant fired her shortly after she proposed an alternative accommodation.
Plaintiff seeks various remedies, including lost wages, emotional distress damages, punitive damages, and attorneys’ fees.