Tenth Circuit: Nurse who Resigned on Advice of Supervisor did not Have claim for Discrimination

In Chaplin v. Park Hospital District, Inc., the Tenth Circuit Court of Appeals ruled that a nurse who resigned her position in reliance upon her supervisor’s statement that she would likely become the new Unit Coordinator could not bring claims for disability discrimination and FMLA violations because the record established that being placed in that position was not a reasonable accommodation since she could not be reassigned to it.  The court also agreed that the statement by the supervisor could not be construed as an implied contract or enforceable promise.