Bartlett v. Dep’t of Treasury

Plaintiff was a long-time employee of the Internal Revenue Service (IRS). Plaintiff was separated from her employment as a result of her inability to return to the workplace resulting from severe depression. Plaintiff filed a complaint against the IRS alleging that she had been constructively discharged on account of her disability in violation of the Rehabilitation Act and the Americans with Disabilities Act. The district court dismissed Plaintiff’s complaint on the ground that Plaintiff had not lodged her administrative complaint within forty-five days of the incident, as statutorily required, thereby rejecting Plaintiff’s contention that equitable tolling applied to her claim. The First Circuit Court of Appeals affirmed, holding that Plaintiff did not establish that equitable tolling should be applied to save her untimely administrative action. View "Bartlett v. Dep't of Treasury" on Justia Law