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Stewart v. St. Elizabeths Hospital and District of Columbia Dep't of Mental Health

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Argued November 5, 2009

Before: TATEL and KAVANAUGH, Circuit Judges, and RANDOLPH, Senior Circuit Judge.

Trina Stewart worked for about 20 years as a housekeeping aide at St. Elizabeths*fn1 Hospital in Washington, D.C. In January 2002, St. Elizabeths transferred Stewart to a part of the hospital known as the John Howard Pavilion, a maximum-security facility that houses mentally ill patients who have been charged with or convicted of crimes. Stewart alleges that the stress of working there caused her mental health to deteriorate to the point that she became disabled for purposes of the Rehabilitation Act. Stewart contends, moreover, that St. Elizabeths failed to accommodate her disability by refusing her request for a transfer to a job site outside the John Howard Pavilion. Stewart’s claim fails, however, because her superiors did not have notice of any mental disability or requested accommodation until October 2002, at which time they acted promptly and appropriately to assist her. We therefore affirm.

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