Calero-Cerezo v. United States Department of Justice

          United States Court of Appeals
                     For the First Circuit

No. 02-2643
                    SYLVIA I. CALERO-CEREZO,

                      Plaintiff, Appellant,

                                v.

          UNITED STATES DEPARTMENT OF JUSTICE, ET AL.,

                     Defendants, Appellees.


          APPEAL FROM THE UNITED STATES DISTRICT COURT
                 FOR THE DISTRICT OF PUERTO RICO

        [Hon. Juan M. Perez-Gimenez, U.S. District Judge]


                             Before

                      Selya, Circuit Judge,
                     Lipez, Circuit Judge,
                  and Ponsor*, District Judge.



     Sylvia I. Calero-Cerezo, pro se.

     Fidel A. Sevillano-Del Rio, Assistant United States Attorney,
with whom H.S. Garcia, United States Attorney, and Miguel A.
Fernandes, Assistant United States Attorney, were on brief for the
United States.


                        January 14, 2004




   *Of the District of Massachusetts, sitting by designation.
            PONSOR, District Court Judge.           This cases raises, among

other issues, the knotty question of how far the Rehabilitation Act

of 1973 ("Rehabilitation Act"), 29 U.S.C. § 701 et seq., requires

an employer to go to accommodate an employee whose disability –

clinically diagnosed major depression – has affected, in some

respects, her ability to function in the workplace.                     The trial

judge,    grappling    with   claims    under    several       statutes,   granted

summary judgment for defendants on all the plaintiff's causes of

action.    Because we find that the record, viewed in the light most

favorable   to   the   appellant,      might    support    a    claim   under   the

Rehabilitation    Act,   and   (equally        importantly)      that   appellees'

counsel has entirely failed to address either the facts or the law

buttressing this claim, we are constrained to reverse and remand

for further proceedings.

                         I. Procedural Background

            A brief review of the procedural history of this case

will serve to put the issues in context.

            After pursuing administrative remedies starting in 1998,

plaintiff-appellant, Sylvia I. Calero-Cerezo ("Calero"), an attorney

employed by the Immigration and Naturalization Service ("INS")

proceeding pro se, filed her complaint in the United States District

Court on October 4, 1999. The defendants were the United States

Department of Justice ("DOJ"), the INS, then-Attorney General Janet

Reno, and then-Commissioner of the INS Doris Meissner.                     Amended


                                       -2-
complaints followed in May 2000 and May 2002.             Perhaps because

plaintiff was representing herself, the precise causes of action

were rather hard to discern from the pleadings.            Plaintiff now

asserts that, while she may have included additional theories in her

administrative proceedings, her complaint and amended complaints as

submitted to the district court were intended to encompass only two

claims: (1) a claim for failure to accommodate her disability under

the Americans with Disabilities Act ("ADA"), 42 U.S.C. § 12101 et

seq.,1 and the Rehabilitation Act, and (2) a claim for retaliation

under Title VII, 42 U.S.C. § 2000e et seq.

            Eventually the parties filed cross-motions for summary

judgment, and on September 18, 2002, the district court issued its

opinion granting the defendants' motion and denying the plaintiff's.

In   his   memorandum,   the   district   court   judge   conscientiously

addressed all causes of action that might reasonably have been

inferred from the plaintiff's less than artfully drafted pleadings,

including claims for discrimination based on gender, national origin

and age, which the plaintiff has not pursued, as well as the claims

for failure to accommodate and for retaliation, which the plaintiff



      1
        This opinion will concentrate almost entirely on the
Rehabilitation Act, since the ADA is not available to federal
employees. Rivera v. Hayman, 157 F.3d 101, 103 (2d Cir. 1998).
The same standards, however, apply to claims under the ADA and
under the Rehabilitation Act. Oliveras-Sifre v. Puerto Rico Dep't
of Health, 214 F.3d 23, 25 n.2 (1st Cir. 2000). The elimination of
the ADA claim does not, therefore, affect the legal analysis or the
scope of remedy available to the plaintiff.

                                   -3-
has continued to press on this appeal.     Specifically, with regard

to plaintiff's claim for failure to accommodate her disability, the

district court suggested, first, that "depression per se" is not

a recognized disability, then went on to conclude that, in any

event, the record conclusively indicated that plaintiff could not

perform the legitimate requirements of her position, and moreover

that plaintiff's requested accommodation was not feasible.

          On November 15, 2002, Calero filed her Notice of Appeal,

challenging only the district court's rulings regarding her claims

for failure to accommodate and for retaliation. Despite clear

notification of the scope of this appeal, and further confirmation

in the appellant's brief, appellees'       counsel has inexplicably

treated this appeal as though it involved merely a garden variety

claim of discrimination under Title VII.   No significant discussion

whatever addresses Calero's claim – the heart of her case – that the

defendants failed to make any reasonable effort to accommodate her

disability.   This neglect has played a substantial part in the

court's decision to remand.

                      II.    Factual Background

          We recount the facts in the light most favorable to

Calero, the party opposing summary judgment. Motorsport Eng'g, Inc.

v. Maserati SPA, 316 F.3d 26, 28 (1st Cir. 2002).

          Calero began practicing law in 1977 in Puerto Rico's

Department of Justice.      Later, she worked for private firms and


                                  -4-
agencies in Puerto Rico, and, from 1993 to 1995, in East Hartford,

Connecticut with the Federal Deposit Insurance Corporation.      In

1995, Calero was hired as an assistant district counsel in the New

York District Office of the INS' Office of the General Counsel

("OGC").   Her performance was rated "excellent" in her 1996-97

appraisal, and in May 1997 Calero successfully petitioned for a

transfer to the San Juan District Office of the OGC, where she began

working part-time as an assistant district counsel.   Nothing in the

record suggests that Calero, up to this point in her twenty-year

career as an attorney, had ever encountered significant difficulties

in performing her job at or above the level of her employers'

expectations.

           During the summer of 1997, Calero began to suffer from

tension headaches and lethargy, the first sign of the onset of a

disability that was soon to erode her capacity to function without

accommodation. On January 16, 1998, Dr. Roberto Rodriguez ("Dr.

Rodriguez") diagnosed Calero with a recurrence of depression and

prescribed the antidepressant Paxil. Calero had suffered previously

from depression, in 1990 when her mother and father died and again

in 1992 upon the death of her brother. The record does not suggest,

however, that at these earlier times her depression interfered with

her capacity to work.

           In February 1998, Calero began working full-time at the

San Juan District Office. One month later, and two months following


                                -5-
her diagnosis of depression, Calero's emotional fragility catapulted

her into the first of a series of acrimonious episodes with her

supervisor Vivian Reyes-Lopez ("Reyes"). Before summarizing the

evidence related to these incidents, two observations about the

state of the record are appropriate.

          First, in recounting her conflicts with Reyes, plaintiff's

pro se papers sometimes appear to suggest that Calero's problems at

work derived not from a failure to accommodate her disability, but

simply from Reyes' general unfairness to her.   To the extent Calero

might succeed in placing blame for her problems at work on Reyes

personally, she may vindicate her own virtue but doom her case. The

Rehabilitation Act is not, of course, designed to provide a worker

a remedy against an arbitrary supervisor, per se.    It is designed

to insure that a capable, disabled worker, covered by the statute,

is not deprived of the opportunity to work and earn a living due to

the refusal of the employer to make a reasonable accommodation.

Viewed in the light most favorable to the plaintiff, therefore, the

summary below will concentrate on facts that a reasonable factfinder

might find supportive of this statutory claim, and not on Calero's

occasional self-justifying suggestions that it was Reyes, not she,

who was responsible for their ongoing problems.

          Second, we are aware in recounting this background that

a reasonable factfinder might conclude that Calero's friction with

her supervisor (and, as will be seen, others including family and


                                -6-
friends) might be explained on the ground that she was simply a very

difficult, not a disabled, person.            In the context of summary

judgment, however, we must respect the role of the factfinder to

choose between alternative, reasonably supported inferences. Since

the   factual   mosaic,   seen   from   plaintiff's     perspective,   might

reasonably support a claim of disability, we summarize the facts in

a manner consistent with that viewpoint.

             The first episode of what was to be a lengthy series of

problems between Calero and Reyes arose over what should have been

a trivial matter. On March 9, 1998, Reyes denied Calero's request

to make up a lost work hour during lunchtime.           In response, Calero

complained in a loud voice that Reyes was the worst supervisor she

ever had and that Reyes treated her like a child.            The outburst was

vociferous enough to be overheard by other INS staff in the office.

             The following day, March 10, 1998, Reyes asked Calero to

come to her office to discuss the previous day's contretemps.              At

the meeting, Reyes told Calero that raising her voice in the office

was not necessary.     Calero responded with a further verbal attack,

criticizing Reyes' supervisory skills, telling Reyes that she had

a bad attitude, and suggesting that Reyes had lost an appointment

as an immigration judge because of her poor professional ability.

             A week later, on March 17, 1999, Calero consulted Dr.

Filia   S.   Garcia,   who   referred     Calero   to   a   psychologist   for

evaluation of her "masked depression."


                                    -7-
             On March 18, 1998, Calero received a formal reprimand (a

so-called memorandum of "admonishment") from Reyes for her behavior

on March 9th and 10th.

             The day following her receipt of this reprimand, Calero

sent an e-mail message to Jack Penca ("Penca"), the Regional

District Counsel and Reyes' immediate supervisor, who worked out of

the Vermont office of the INS, regarding the recent friction with

Reyes.   Calero complained to Penca that Reyes was harassing her and

that this daily harassment was affecting her emotionally.              Calero

informed Penca that she was taking the antidepressant Paxil "to be

able to continue working."       This was the first time Calero informed

a supervisor that she was suffering from depression and was on

medication for her condition.

             In mid-April 1998, Calero was seen by psychiatrist Dr.

Margarita Alonso Cedo ("Dr. Alonso").            On April 13th, Calero's

condition was serious enough that Dr. Alonso recommended to Calero

that she take a medical leave from work for the next three weeks.

On   April   17,   1998,   Dr.   Alonso    diagnosed   Calero   with   "major

depression" and, like Dr. Rodriguez in January 1998, prescribed the

antidepressant Paxil.

             Significantly, Dr. Alonso also wrote a note to Calero's

employer giving notice of Calero's condition and confirming her

recommendation that Calero take a three-week break from work. After

receiving two doctors' notes from Dr. Alonso explaining Calero's


                                     -8-
diagnosis,     medication    and    plan      for    treatment,     Reyes      approved

Calero's sick leave, which lasted from April 14 to May 1, 1998.

           On April 21, 1998, Calero contacted the Office of Equal

Employment Opportunity, Immigration and Naturalization Service, U.S.

Department of Justice ("EEO") in Washington, D.C. to inquire about

filing a complaint for discrimination and harassment.                  On April 22,

1998,    Calero   contacted     Dr.      Ruth       Prevor   ("Dr.    Prevor"),       a

psychologist with the INS Employee Assistance Office.                     Thereafter,

Calero   met   with    Dr.   Prevor      on    several   occasions        to    receive

assistance regarding her mental disability.

             Also on April 22nd, while Calero was on medical leave,

Reyes left Calero two memoranda instructing Calero to complete

certain tasks in preparation for her upcoming annual vacation.

Reyes asked Calero to review her cases scheduled for hearings in the

immigration    court   during      her   vacation      and   also    to     prepare   a

particular case to be discussed with Reyes before the vacation's

starting date, which was May 22, 1998.

             On May 7, 1998, after Calero returned from her medical

leave but before she left for her annual vacation, Calero and Reyes

met to discuss Calero's cases.           Reyes had previously requested that

Calero copy her on certain e-mail messages, and Calero again entered

into a nasty argument with Reyes, this time about Reyes' concern

that Calero was failing to follow Reyes' instructions.                    Calero told

Reyes during this conversation that Reyes was reprimanding her as


                                         -9-
a mother might scold a child and treating her unfairly.   At the end

of the meeting, Calero asked, with heavy sarcasm, "Is that all

Vivian?   Can I leave now?"   Later, when Reyes approached Calero's

desk and asked her why she had again failed to copy her on an e-mail

as requested, Calero became furious and told Reyes to stop scolding

her, that she was not a child and Reyes was not her mother.

Bizarrely, Calero began calling Reyes "mother" and "mommy," refused

to provide Reyes an explanation of why she did not copy Reyes on

e-mail messages as Reyes had instructed, and repeated, "Don't punish

me, stop punishing me."    Again, this strange and confrontational

behavior was observed by other INS employees.

           Not surprisingly, Reyes reported Calero's conduct to

Penca.    Her memo summarized the May 7th incident and recommended

that disciplinary action be taken against Calero.   Reyes indicated

that Calero was a "disruptive element" and recommended that Calero

either be dismissed or transferred out of the San Juan District

office.

           On May 11, 1998, Calero mailed Penca a copy of her EEO

complaint, and informed him that she had been getting counseling

from the EEO office of the INS and that she was submitting the

complaint to her EEO counselor. Penca subsequently forwarded a copy

of the complaint to Reyes.

           On May 22, 1998, Calero went on her scheduled two-week

annual leave, returning to work on June 2, 1998.    Before she left


                                -10-
Calero   failed    to     prepare       her    cases    properly,    as     Reyes   had

instructed.

           On   May      26,    1998,    Reyes   sent    a     memorandum    to   Penca

detailing Calero's failure to review her files, as requested. Reyes

noted that, in order to prepare the cases with hearings scheduled

during the two weeks Calero was out, she and another OGC attorney

had been required to work ten hours of overtime.

           On June 22, 1998, Penca sent Calero a Notice of Proposed

Ten Day Suspension ("Notice").            The two grounds for this suspension

were: (1) Calero's disrespectful behavior toward Reyes on May 7,

1998, and (2) Calero's disregard of Reyes' instruction to prepare

her cases before going on leave.               Calero submitted a 35-page reply

in opposition to this Notice.

           On     July    23,    1998,    Calero       received    her    performance

appraisal for July 1, 1997, through June 30, 1998.                  Calero received

a "minimally satisfactory" rating in the category of "Advocates

for/Represents      the    Agency"       but    was    given    ratings     of    "fully

successful" in categories of "Provides Legal Advice" and "Conducts

Legal Research and Writing." Her formal rating, overall, was "fully

successful."

           Despite these rather positive ratings, Calero received

several negative comments in her review.                 For example, the review

noted that Calero failed to prepare several of her cases for

hearings, that she failed to inform her supervisor of the status of


                                         -11-
her cases and that she required substantial supervision.                Despite

her titularly satisfactory ratings, Calero viewed this as the first

negative review that she had received during her employment with the

INS.

              On June 24, 1998, Dr. Alonso again recommended that Calero

take a few days off from work to rest, and Calero did so.

              Despite the rest, it was clear by the middle of the summer

that Calero's depression was infecting her relations with persons

other than her supervisor.         In a memo dated August 12, 1998, Reyes

noted      Calero's    excessive   and   unwarranted       criticism   of   other

attorneys, evident in the e-mails she was sending to lawyers outside

the office.

              On August 17, 1998, at Dr. Alonso's recommendation, Calero

was "partially" hospitalized for ten days due to her depression.2

In addition, side effects from the antidepressant medication were

troubling     Calero    to   the   extent    that    Dr.   Alonso   changed   her

prescription.

              Following her partial hospitalization, on September 1,

1998, Calero sent an e-mail entitled "transfer on detail" to Paul

Virtue, General Counsel, INS ("Virtue"), with a copy to David Dixon,

Deputy General Counsel, INS ("Dixon").              Calero informed Virtue and

Dixon that she had been suffering from major depression since April



       2
       The record does not indicate what is meant by "partial"
hospitalization.

                                      -12-
13, 1998, and that she was being discriminated against and harassed

by her supervisors, Reyes and Penca. She noted, among other things,

INS' duty to consider a reasonable accommodation that would allow

her to perform her job. As her own suggestion for an accommodation,

she requested a temporary assignment (a so called "detail") out of

her   current      work   site,     to    the    INS    office      at    the   San     Juan

International Airport.

            The September 1, 1998, e-mail was the first of what would

be many explicit requests for some sort of an accommodation, or at

least a dialogue concerning accommodation, to permit plaintiff to

continue    working       while    she    received      treatment        for    her   major

depression.        The    specific       accommodation       proposed      by    Calero    –

temporary assignment to the San Juan airport – may perhaps have

presented certain practical problems for the INS. The record is not

clear on this point, and, again, the appellees' failure to offer any

discussion on the issue has handcuffed the court.                          It is clear,

however,    that    Calero's       employer      made   no   effort       to    offer    any

realistic    alternative          accommodation,        or   even    to    discuss       the

difficulties that plaintiff's major depression was creating for her

at work.

            On September 4, 1998, Calero once again sent an e-mail

notification to Virtue, with a copy to Dixon, to the effect that the

lack of any response by the INS to her complaints was causing a

deterioration of her physical and emotional health, and that she was


                                          -13-
requesting an alternative assignment as a reasonable accommodation

for her disability of depression.

           On September 8, 1998, a simmering problem related to

Calero's apparent tape recording in the office boiled over. In June

of 1998, some co-workers of Calero's had told Reyes that they

thought that Calero was taping their conversations.     In response,

Reyes sent out an e-mail reminding all staff that surreptitious tape

recording of conversations was impermissible, against INS policy,

and could result in discipline.     On September 8th, a staff member

told Reyes that she observed Calero using a tape recorder while

talking with Reyes.   Reyes approached Calero, obtained the recorder

after some argument and found that, indeed, the tape contained a

recording of her conversation. When Reyes told Calero she was going

to take the tape, Calero screamed at her and tried to block the

doorway.   After she managed to make her exit, Reyes turned the tape

over to the local FBI office.

           Some months later, in a letter to Penca, dated January 20,

1999, Calero claimed that someone in the office had been attempting

to tape her conversations without her knowledge in order to "frame"

her.   She asserted that she taped Reyes inadvertently, unaware that

the tape recorder was turned on.

           On September 14, 1998, after the screaming incident over

the tape recorder, Dr. Alonso recommended that Calero take a medical

leave from work for two weeks.


                                 -14-
            On October 7, 1998, Dixon suspended Calero for five days

for disrespectful behavior toward her supervisor and for failure to

follow orders.     Dixon based his decision on Penca's Notice of

Proposed Action issued on June 22, 1998, Calero's response, and

Reyes' memorandum of admonishment of March 18, 1998.

            Later in October, Calero e-mailed Virtue a third time and

again requested a temporary assignment to the INS Airport office in

San Juan.    Once more, she received no response.

            On October 30, 1998, when a new attorney was being hired

in the office, Reyes contacted Calero and gave her the choice of

either accepting replacement furniture for her office and keeping

her office, or keeping her newer furniture and turning her office

over to the new attorney.   Calero chose to keep her newer furniture

and was moved to a less desirable work area, described by Calero as

a "grot."

            On November 2, 1998, Dr. Alonso observed, in a handwritten

note on a prescription pad, that Calero should be transferred to a

different workplace in Puerto Rico so that "she could benefit from

continued treatment, decreased stressful situations and family

support."     It is not clear whether this notation reached the

defendants.

            The following day, Calero faxed Virtue her fourth request

for an accommodation.    She detailed the medical treatment she was

receiving, described the discrimination and harassment she perceived


                                 -15-
herself as suffering and emphasized her concern that her depression

was affecting her job performance.      Significantly, Calero disclosed

to Virtue that her problems went beyond her relationship with Reyes:

          Due to the depression, I have detached myself
          from my family and friends, who have been very
          worry [sic] about me and had been reaching me
          and giving me support. My social life had been
          extremely limited.

In this November 3, 1998, letter, Calero again asked for a transfer

to the San Juan International Airport office.      Again, the INS made

no response.

          On   November   9,   1998,      Dr.   Alonso   made   another

recommendation that Calero absent herself from work in order to rest

for the remainder of the week.    Three days later, Calero made yet

another request to be transferred to the San Juan International

Airport office in a letter to Virtue.     At the end of that month, Dr.

Alonso recommended Calero rest from work for ten days starting

November 27, 1998.

          On December 9, 1998, Reyes issued a Notice of a Proposal

of Suspension of Calero for fourteen days for (1) failure to follow

orders by surreptitiously tape-recording conversations in the office

on September 8, 1998; (2) failure to follow orders by refusing to

update Reyes on a particular case; and (3) failure to be forthright

with a supervisor by taping conversations in the office and then

denying doing so.




                                 -16-
            On December 15, 1998, Michael Coaster, a Division Chief

with the INS' Office of the General Counsel ("Coaster"), denied

Calero's requests for an accommodation.            His letter stated:

            You wrote that you are depressed because "of
            the discrimination and harassment based on sex
            and national origin that (you) have endured
            within the INS San Juan District Office." This
            is not a disability as defined by the
            Rehabilitation Act of 1973 and the Age
            Discrimination in Employment Act. As such, the
            agency is not under an obligation to provide
            you with an accommodation.

            This letter made no mention of the medical evidence

submitted by Calero confirming her major depression.              The Coaster

letter did indicate that the INS had at some unspecified time

offered   to   consider   reassigning     Calero    to   an   existing    vacant

position outside Puerto Rico, but that Calero had rejected this

offer because she did not want to leave Puerto Rico.               Except for

this reference in the Coaster letter, no documentation exists in the

record memorializing this supposed offer to transfer Calero.                    No

details specify the location or nature of the new position, the

timing of the supposed transfer, or the identity and authority of

the person making the offer.

            On February 4, 1999, Calero filed her second EEO complaint

alleging discrimination based on gender, national origin, age,

mental and physical disability, and retaliation.

            On February 16, 1999, Penca found the second ground of

Reyes'    Proposed   Suspension   of   December     to   be   supported    by    a


                                   -17-
preponderance of the evidence.     Penca determined that disciplinary

action for Calero's failure to follow orders in reporting to Reyes

the status of a case was warranted and imposed a ten day suspension

without pay on February 16, 1999. In response, Calero filed several

complaints     with   law   enforcement    agencies    calling    for   an

investigation    of   the   supposed   illegal   tape-recording   of    her

conversations by coworkers.

          On April 6, 1999, Reyes reminded Calero that she was late

for an appearance before an immigration judge.        In response Calero

falsely denied that she was late. It later emerged that the judge

had been kept waiting because of Calero's tardiness.

          In early May 1999, Calero was involved in yet another

unseemly office incident.       Calero told a student-employee, Lenga

Siberon ("Siberon"), to be on guard for "illegal things" that Reyes

might ask her to do.         Siberon replied that she was not doing

anything illegal. In a written statement provided to Reyes, Siberon

reported that she felt "intimidated and somewhat threatened" by

Calero.

             On June 4, 1999, a second disturbing incident involving

Calero and a different student-employee occurred.           The student,

Carmen Ortiz ("Ortiz"), did not interrupt a meeting to give Calero

two telephone messages from Calero's son.        Calero exploded at Ortiz

for not giving her the messages immediately, screaming at the young

woman and berating her.


                                  -18-
             On    June   11,   1999,    Calero's   counsel,   Miriam   Ramos

Grateroles, faxed a letter to Doris Meissner, the Commissioner of

the   INS.        Calero's counsel requested that Calero be given          a

reasonable accommodation in accordance with the Rehabilitation Act

and that she be transferred to the Airport office.             She also wrote

that the conduct and behavior of Reyes was the principal factor

underlying Calero's major depression and that some separation from

Reyes and the environment at the San Juan office would allow Calero

to continue to work despite her disability.           Calero's counsel also

included a note from Dr. Alonso, which reported that Calero was

having difficulty interacting with family and friends due to her

depression.       The doctor recommended that any transfer of Calero be

within Puerto Rico, so that Calero could receive needed family and

community support to the extent possible during her illness.

             At work, plaintiff's behavioral manifestations of her

severe depression continued.        During the spring and summer of 1999,

Reyes reported to Penca that Calero was at various times "agitated,"

"out of control," "impossible to work with," "bizarre," and "a

constant source of aggravation."               On July 9, 1999, during a

discussion of a scheduling conflict, Calero repeatedly stated in a

loud voice, in the presence of two other employees, that Reyes was

harassing her on a daily basis, and that her absences were due to

Reyes' constant humiliation.




                                        -19-
          The final blow-up between Calero and Reyes occurred four

days later.    Again, the trigger for the eruption should have been

a routine matter.    Reyes instructed Calero to leave for court so

that she would be on time.   In a raised voice, Calero called Reyes

a liar and stated that Penca and Reyes had made false accusations

against her and fabricated evidence against her.   Once again, other

employees were in the area and overheard the contentious exchange

between the two.

          The following day, July 14, 1999, Reyes placed Calero on

paid administrative leave, where she remained until her termination

the following May.

          On January 3, 2000, Bo Cooper, General Counsel of the INS,

issued a Notice of Proposed Removal to Calero. The Notice was based

on four specific grounds: (1) making statements to a co-worker that

advocated the mistrust of a mutual supervisor and resulted in

anxiety in the workplace; (2) disruptive behavior; (3) conduct

unbecoming    a Service attorney; and (4) disrespectful behavior

towards a supervisor.

          On May 4, 2000, Marc Salans ("Salans"), Assistant Director

of the Office of Attorney Personnel Management of the Department of

Justice, found Calero's removal warranted and made her termination

effective as of May 19, 2000.




                                -20-
                        III.   Standard of Review

            We review a district court's ruling on cross-motions for

summary judgment de novo. See Bienkowski v. Northeastern Univ., 285

F.3d 138, 140 (1st Cir. 2002); Wightman v. Springfield Terminal Ry.

Co., 100 F.3d 228, 230 (1st Cir. 1996).

            Summary judgment is appropriate when "the pleadings,

depositions, answers to interrogatories, and admissions on file,

together with the affidavits, if any, show that there is no genuine

issue as to a material fact and that the moving party is entitled

to a judgment as a matter of law."            Fed. R. Civ. P. 56(c).        A

"genuine" issue is one that could be resolved in favor of either

party, and a "material fact" is one that has the potential of

affecting the outcome of the case.         See Anderson v. Liberty Lobby,

Inc., 477 U.S. 242, 248-50 (1986).

            Once the moving party has asserted that no genuine issue

of material fact exists, the burden is on the opposing party to

point to specific facts demonstrating that there is, indeed, a

trialworthy issue.      Nat'l Amusements, Inc. v. Town of Dedham, 43

F.3d 731, 735 (1st Cir. 1995).     Not every genuine factual conflict,

of course, necessitates a trial.      "It is only when a disputed fact

has the potential to change the outcome of the suit under the

governing   law   if   found   favorably    to   the   nonmovant   that   the

materiality hurdle is cleared."            Parrilla-Burgos v. Hernandez-

Rivera, 108 F.3d 445, 448 (1st Cir. 1997) (citation omitted).


                                   -21-
            On the other hand, to survive summary judgment a plaintiff

is not required to rely only on uncontradicted evidence.         Medina-

Munoz v. R.J. Reynolds Tobacco Co., 896 F.2d 5, 9 n.3 (1st Cir.

1990).    In this case, as noted, the record as a whole presents many

inconsistencies, displaying perspectives that favor in some lights

the defendants and in others the plaintiff.             So long as the

plaintiff's evidence is both cognizable and sufficiently strong to

support a verdict in her favor, the factfinder must be allowed to

determine which version of the facts is most compelling.

                            IV.   Discussion

            Two issues are in play in this appeal: first, whether on

the   record   a   reasonable   factfinder   might   conclude   that   the

defendants violated the Rehabilitation Act by failing to offer

Calero a reasonable accommodation for her disability;             second,

whether a factfinder might reasonably find that the defendants

violated Title VII by retaliating against Calero for asserting her

rights.    We begin with the claim under the Rehabilitation Act.

            A. Discrimination Based on Disability

            The ADA and Rehabilitation Act prohibit discrimination

against an otherwise qualified individual based on his or her

disability.     The Rehabilitation Act, the precursor to the ADA,

applies to federal agencies, contractors and recipients of federal

financial assistance, while the ADA applies to private employers

with over 15 employees and state and local governments.         Although,


                                  -22-
as noted supra n.1, the ADA does not apply here, the case law

construing the ADA generally pertains equally to claims under the

Rehabilitation Act.

          The federal statutes barring discrimination based on

disability do more than merely prohibit disparate treatment; they

also impose an affirmative duty on employers to offer a "reasonable

accommodation" to a disabled employee.   42 U.S.C. § 12112(b)(5)(A).

García-Ayala v. Lederle Parenterals, Inc., 212 F.3d 638, 646 n.9

(1st Cir. 2000).

          To assert a claim for failure to accommodate under the

Rehabilitation Act, Calero would have to establish the following:

(1) that she suffered from a "disability" within the meaning of the

statute; (2) that she was a qualified individual in that she was

able to perform the essential functions of her job, either with or

without a reasonable accommodation; and (3) that, despite her

employer's knowledge of her disability, the employer did not offer

a reasonable accommodation for the disability. See Carroll v. Xerox

Corp., 294 F.3d 231, 237 (1st Cir. 2002); Higgins v. New Balance

Athletic Shoe, Inc., 194 F.3d 252, 264 (1st Cir. 1999). We will

address each of these three elements separately.3




     3
      Two other elements, sometimes noted, require no discussion.
It is undisputed that the defendants are covered by the
Rehabilitation Act, and that plaintiff suffered in the terms and
conditions of her employment.

                               -23-
          1. Disability

          The ADA defines "disability" as either (a) a physical or

mental impairment which substantially limits one or more of an

individual's major life activities; (b) a record of such impairment;

or (c) being regarded as having such an impairment.      42 U.S.C. §

12102(2); see also 29 C.F.R. § 1630.2(g). Here, plaintiff contends,

under subsection (a), that she actually suffered a mental impairment

that limited one or more of her major life activities.

           It is well established that the determination of whether

a plaintiff has a disability must be made on a case-by-case basis.

See Toyota Motor Mfg., Ky., Inc. v. Williams, 534 U.S. 184, 198

(2002); Sutton v. United Airlines, Inc., 527 U.S. 471, 483 (1999).

The analysis leading to this determination requires the court to

consider the record in the light of three questions. First, did the

plaintiff suffer a physical or mental impairment?    Second, did the

"life activity" limited by the impairment qualify as "major"?

Finally, did the impairment, in fact, substantially limit the

plaintiff's identified major life activity?    See Bragdon v. Abbott,

524 U.S. 624, 630-31 (1998).    The burden is on the plaintiff to

establish these three elements.       See Bailey v. Georgia-Pacific

Corp., 306 F.3d 1162, 1167 (1st Cir. 2002); Carroll, 294 F.3d at

238.   We now take up these three inquiries.




                               -24-
          a. Did the Plaintiff Suffer a Mental Impairment?

          The answer to the first question, on the facts of this

case, is obviously in the affirmative.   This circuit has recognized

depression as a mental impairment that may constitute, at least in

some circumstances, a disability under federal law.   See Criado v.

IBM Corp., 145 F.3d 437, 442 (1st Cir. 1998).     A number of other

circuits have also recognized depression as a qualifying mental

impairment.    See, e.g., Ogborn v. United Food & Commercial Workers

Union, Local No. 881, 305 F.3d 763, 767 (7th Cir. 2002) ("Major

depression can constitute a disability under the ADA."); Snead v.

Metro. Prop. & Cas. Ins. Co., 237 F.3d 1080, 1088 n.8 (9th Cir.

2001) ("In Oregon, stress and depression can be considered mental

impairments.    The same is true under the ADA."); Pritchard v.

Southern Co. Servs., 92 F.3d 1130, 1132 (11th Cir. 1996), amended

in part on reh'g, 102 F.3d 1118, cert. denied, 520 U.S. 1274 (1997)

("Depression has been held to constitute a mental impairment."); Doe

v. Region 13 Mental Health-Mental Retardation Comm'n., 704 F.2d

1402, 1408 (5th Cir. 1983) (same).

          Moreover, the record in this case provides more than

sufficient evidence to permit a factfinder to conclude that the

plaintiff, in fact, was suffering from major depression during the

relevant period.    The record confirms Calero's prior history of

depression, her diagnosis of depression by at least two physicians,

her antidepressant medication, her numerous required medical leaves


                                -25-
from work, and her partial hospitalization.   In sum, as a matter of

law and of fact, the record clearly favors the plaintiff on the

first of the three pertinent questions.    A factfinder could easily

determine that she suffered a qualified mental impairment.       To

determine whether the record would support a finding that plaintiff

suffered a disability, we now turn to the next question.

          b.     Did the Plaintiff's Mental Impairment Limit
                 a "Major" Life Activity?

          Calero has highlighted numerous life activities that she

says were limited by her depression: sleeping, eating, learning,

concentrating, thinking, working and interacting with others.      A

"major life activity" is an activity of central importance to

people's daily lives.   Toyota Motor, 534 U.S. at 197.   Many of the

activities cited by the plaintiff have been recognized, by this

court or others, as "major," including sleeping and eating, Criado,

145 F.3d at 442-43; Lawson v. CSX Transp., Inc., 245 F.3d 916, 923

(7th Cir. 2001), learning, Bercovitch v. Baldwin Sch., Inc., 133

F.3d 141, 155 (1st Cir. 1998), and thinking and concentrating,

Whitney v. Greenberg, Rosenblatt, Kull & Bitsoli, P.C., 258 F.3d.

30, 33 n.4 (1st Cir. 2001).   The Supreme Court has assumed, without

deciding, that working itself may be considered a major life

activity for purposes of the ADA.         Sutton, 527 U.S. at 492.

Likewise, this court has on occasion assumed arguendo that working

might be deemed a major life activity under the Rehabilitation Act.

See, e.g., Bailey, 306 F.3d at 1168 n.5; Carroll, 294 F.3d at 239;

                                -26-
Gelabert-Ladenheim v. American Airlines, Inc., 252 F.3d 54, 58 (1st

Cir. 2001).

            In granting summary judgment        for the defendant, the

district court did not take issue with plaintiff's claim that her

disability interfered with one or more of these recognized major

life activities.      Moreover, as noted, the appellees' brief has

offered us not a word of discussion on the issue.          In view of the

documented severity of plaintiff's disability, we assume that the

defendants concede, at least for purposes of summary judgment, that

it interfered with one      or   more of the major life activities

specified by Calero.

            c. Was the Major Life Activity "Substantially" Limited?

            It is a simple matter to find sufficient evidence in the

record that Calero's mental impairment did "substantially" limit a

major    life   activity.   Although     the   federal   statutes   do   not

explicitly define the phrase "substantially limits," in Sutton the

Supreme Court instructed that the phrase "suggests 'considerable'

or 'specified to a large degree.'"       Sutton, 527 U.S. at 491.        Even

so,     "while substantial limitations should be considerable, they

also should not be equated with 'utter inabilities.'"           Taylor v.

Phoenixville Sch. Dist., 184 F.3d 296, 307 (3d Cir. 1999). The

Supreme Court has stated that "[w]hen significant limitations result

from an impairment, the disability definition is met even if the

difficulties are not unsurmountable."          Bragdon, 524 U.S. at 641.


                                  -27-
An impairment can substantially limit a major life activity, even

though the plaintiff is still able to engage in the activity to some

extent.     See Gillen v. Fallon Ambulance Serv., Inc., 283 F.3d 11,

22 (1st Cir. 2002).

            As before, neither the district court nor the appellees

here have contested Calero's assertion that her major depression

substantially limited one or more of her recognized major life

activities.        Given this, we must conclude by default that the

evidence was sufficient to satisfy the first element of Calero's

Rehabilitation Act claim; she did suffer a "disability."                  The next

question is whether she was a "qualified individual." Was she able

to perform the essential functions of her job, with or without an

accommodation?

            2. Qualified Individual

            To be a "qualified individual" under the Rehabilitation

Act, a plaintiff must show first that she possesses the requisite

skill, experience, education and other job-related requirements for

the position and, second, that she is able to perform the essential

functions     of     the   position     with     or       without   a   reasonable

accommodation.       García-Ayala, 212 F.3d at 646.

            An     "essential   function"      is     a   fundamental    job   duty

associated with a particular position; this function can extend

beyond    "'an     employee's   technical      skills      and   experience,   even

including    such    individual   or    idiosyncratic         characteristics    as


                                       -28-
scheduling flexibility.'"           Ward, 209 F.3d at 34 (quoting Laurin v.

Providence Hosp., 150 F.3d 52, 59 n.6 (1st Cir. 1998)).

            In this case, the evidence shows that Calero was an

experienced trial attorney. She practiced law for over twenty years

and had two successful years of prior experience in this same

position in the INS' New York Office.             She received above average

to excellent performance reviews through June 30, 1998.                     Based on

this,   a   factfinder      might    easily   find     that   she    possessed    the

requisite    skill    and   experience     for   the    position      of   Assistant

District Counsel.

            A much closer question is whether a reasonable factfinder

could conclude that Calero, while suffering the powerful effects of

her disability, still possessed the ability to function competently

and productively in the workplace, either without any modification

of her work situation or with a reasonable accommodation.                        After

all, an employee who is unable to control her bizarre and disruptive

behavior may be unfit for employment, no matter how advanced her

objective    skills    or    how    extensive    her    experience.         Although

appellees' brief ignores the issue entirely, the district court

anchored its summary judgment ruling, in part, on its conclusion

that the record indisputably confirmed plaintiff's inability to

perform her job at an acceptable level.

            A plaintiff offering a claim under the Rehabilitation Act

confronts    a   potential     "Catch-22"     when     arguing      that   she   is   a


                                       -29-
qualified individual under the Act.            She must show both that her

impairment substantially limits a major life activity and that she

is "otherwise qualified" for her job, meaning she is able to perform

the essential functions her position requires, or would be if

reasonably    accommodated.        In   shorthand,     the   law   requires       the

individual     to   be   both    substantially       limited     and     reasonably

functional.     Several authors have discussed this quandary.                  E.g.,

Jonathan Brown, Defining Disability in 2001: A Lower Court Odyssey,

23 WHITTIER L. REV . 335, 381-85 (2001); Chai R. Feldblum, Definition

of Disability under Federal Anti-Discrimination Law: What Happened?

Why? And What Can We Do About It?; 21 BERKELEY J. EMP . & LAB . L. 91,

160-61 (2000); Randal I. Goldstein, Note, Mental Illness in the

Workplace after Sutton v. United Airlines, 86 CORNELL L. REV . 927, 944

(2001).

             This   court   need    not    explore    the      nuances    of     this

interesting conundrum, since the record in this case is adequate to

generate an issue for consideration by a factfinder regarding

plaintiff's capacity to perform her job, even while suffering her

major depression, with or without an accommodation. The defendants'

own evaluation, issued less than a year before plaintiff ceased

working for the INS and several months after Calero's attack of

depression, gave Calero a job rating, not merely of average, but of

"fully    successful."      In   other    words,     despite    some     flaws    and

problems, the INS pronounced itself fully satisfied with Calero's


                                        -30-
level   of   performance     even      while    she   suffered    from   her    major

depression.       Contrary facts produced at a trial may very well put

in play the question of Calero's capacity to perform, but this

documentation alone entitles the plaintiff to consideration by a

factfinder of the second element of her claim.

             To    satisfy   the       third    and    final     element   of     her

Rehabilitation Act claim, plaintiff must prove that her employer,

having knowledge of her disability, failed to offer her a reasonable

accommodation.

             3. Reasonable Accommodation

             If an employer, aware of an employee's disability, refuses

to provide a requested reasonable accommodation, the                       employer

violates the Rehabilitation Act, unless it can show that the

proposed     accommodation       would   pose    an   undue     hardship   for    its

business.     See Higgins, 194 F.3d at 264.

             Reasonable accommodations may include "job restructuring,

part-time or modified work schedules, reassignment to a vacant

position . . . and other similar accommodations for individuals with

disabilities." 42 U.S.C. § 12111(9) (B). A careful, individualized

review of an accommodation request in light of the specific facts

of   the   case    is   needed    to   determine      whether    the   request    was

reasonable. García-Ayala, 212 F.3d at 647.

             To show that a proposed accommodation was reasonable, a

plaintiff must prove "not only that the proposed accommodation would


                                         -31-
enable her to perform the essential functions of her job, but also

that, at least on the face of things, it is feasible for the

employer under the circumstances."      Reed v. LePage Bakeries, Inc.,

244 F.3d 254, 259 (1st Cir. 2001).       The request for accommodation

must be "'sufficiently direct and specific,' giving notice that she

needs a 'special accommodation.'"        Id. at 261 (quoting Wynne v.

Tufts Univ., 976 F.2d 791, 795 (1st Cir. 1992)).

            If the plaintiff offers proof that a sufficiently specific

request was made, the defendant may attempt to prove that, in fact,

the proposed accommodation was not feasible and would constitute an

"undue" hardship.      Id.    An adequately supported denial of an

accommodation request requires the employer "to produce at least

some modicum of evidence showing that the [requested accommodation]

would be a hardship, financial or otherwise." Ward, 209 F.3d at 37.

            In some cases, a request for a reasonable accommodation

may trigger a responsibility on the part of the employer to enter

into an interactive process with the employee to determine an

appropriate accommodation.    Reed, 244 F.3d at 262 n.11.      The ADA's

regulations state that "it may be necessary for the covered entity

to initiate an informal, interactive process with the qualified

individual."    29 C.F.R. § 1630.2(o) (1) (iii).       The scope of the

employer's obligation in this process is not crystal clear, but

"[t]he employer has at least some responsibility in determining the

necessary   accommodation,"   since     "the   regulations   envision   an


                                 -32-
interactive process that requires participation by both parties."

29 C.F.R. § 1630.2(o) (3).

           As     this   court   has   noted,       this   interactive     process

"requires a great deal of communication between the employee and

employer."   García-Ayala, 212 F.3d at 648 n.12, citing Criado, 145

F.3d at 444.      An employer's refusal to participate in the process

may itself constitute evidence of a violation of the statute.                     See

Jacques v. Clean-Up Group, Inc., 96 F.3d 506, 515 (1st Cir. 1996)

("There may well be situations in which the employer's failure to

engage in an informal interactive process would constitute a failure

to provide a reasonable accommodation that amounts to a violation

of the ADA.").

           Other circuits have also found that both the employee and

a   responsible    representative      of     the   employer   have    a   duty    to

participate in this process. See, e.g., Mengine v. Runyon, 114 F.3d

415, 420 (3d Cir. 1997) ("We agree that both parties have a duty to

assist in the search for an appropriate reasonable accommodation and

to act in good faith."); Beck v. Univ. of Wis. Bd. of Regents, 75

F.3d 1130, 1135 (7th Cir. 1996) ("A party that obstructs or delays

the interactive process is not acting in good faith.                  A party that

fails to communicate, by way of initiation or response, may also be

acting in bad faith.      In essence, courts should attempt to isolate

the cause of the breakdown and then assign responsibility."); Taylor

v. Principal Fin. Group, Inc., 93 F.3d 155, 165 (5th Cir. 1996)


                                       -33-
("[O]nce an accommodation is properly requested, the responsibility

for fashioning a reasonable accommodation is shared between the

employee and employer.    Thus, it is the employee's initial request

for accommodation which triggers       the employer's obligation to

participate in the interactive process of determining one.").

          Viewing the facts of this case in the light of these

principles, and faced yet again with an utter lack of argument on

this point by appellees' counsel, the court must conclude that the

evidence regarding reasonable accommodation, while conflicting, is

sufficient to generate an issue for a factfinder when viewed in the

light most favorable to the plaintiff.    First, Calero requested an

accommodation on at least six occasions, specifically identifying

a transfer as an acceptable form of accommodation. Second, Calero's

supervisor, Reyes - usually her adversary - seconded Calero's

request by suggesting the transfer herself.     Third, on the record

as it stands, a factfinder could find that Calero's suggestion of

a transfer to a work site at the San Juan airport was "at least on

the face of things" feasible.   Fourth, a factfinder could also find

that the defendants failed to offer a sufficient "modicum of

evidence" showing that the accommodation proposed by plaintiff would

constitute a hardship.4   Fifth, even if the proposed accommodation


     4
       At oral argument, appellees' counsel dismissed the notion of
a transfer to the INS office at the San Juan airport,
characterizing it as, essentially, unworkable and unprecedented.
The record of the case, however, offers no concrete evidence of any
justification offered by the defendants to support their rejection

                                -34-
might in some way have been less than ideal from defendants'

viewpoint – for reasons not articulated anywhere in the record – a

factfinder could well find that the defendants failed to engage in

any good faith interactive process to explore whether some variant

of the plaintiff's proposal might have been workable.     Indeed, a

factfinder might well conclude that, in the face of plaintiff's

increasingly desperate requests for an accommodation, the defendants

simply stonewalled – going so far as to deny, in the face of

substantial medical evidence, that plaintiff suffered a disability

at all.   Finally, to the extent that the record hints that the

defendants, at some unspecified point and in some unspecified way,

offered a transfer out of Puerto Rico as an accommodation (and the

record supplies only a wisp of indirect evidence on this point), a

factfinder could well conclude that the offer was either grossly

inappropriate, given plaintiff's medical condition, or lacking in

good faith.

          In sum, the record offers sufficient evidence from which

a factfinder could conclude that the defendants, being aware of

plaintiff's disability and of her request for accommodation, failed

to make a reasonable response.     Given that the record contains

evidence that, if believed by a factfinder, might have proved (1)

that Calero did suffer from a disability within the meaning of the

statute, (2) that she was a qualified individual who was able to


of the requested accommodation.

                               -35-
perform the functions of her job, and (3) that her employer failed

to reasonably accommodate her disability, plaintiff was entitled to

present her Rehabilitation Act claim to a factfinder.

          B. Title VII Retaliation Claim

          To   prove   a   claim   of   retaliation,   a   plaintiff   must

establish that (1) she engaged in protected conduct; (2) she

experienced an adverse employment action; and (3) there was a causal

connection between the protected conduct and the adverse employment

action.   See Gu v. Boston Police Dep't., 312 F.3d 6, 14 (1st Cir.

2002).

          The district court held that Calero did prove the first

two elements of her retaliation claim. She did engage in protected

activity by filing her two complaints with the INS' EEO office, and

she was subjected to adverse employment actions. However, the court

held that the evidence was insufficient, even viewed in the light

most favorable to the plaintiff, to prove a causal connection

between the protected activity and the adverse employment actions.

           Calero relies primarily on the timing of the employment

actions as her primary evidence of causal connection. The Supreme

Court has stated that "[t]he cases that accept mere temporal

proximity between an employer’s knowledge of protected activity and

an adverse employment action as sufficient evidence of causality to

establish a prima facie case uniformly hold that the temporal

proximity must be 'very close.'"           Clark County Sch. Dist. v.


                                   -36-
Breeden, 532 U.S. 268, 273-74 (2001) (citation omitted).               Three and

four month periods have been held insufficient to establish a causal

connection based on temporal proximity.            See Richmond v. ONEOK,

Inc., 120 F.3d 205, 209 (10th Cir. 1997); Hughes v. Derwinski, 967

F.2d 1169, 1174-75 (7th Cir. 1992).           We have held that "a showing

of   discharge   soon    after   the   employee   engages    in   an    activity

specifically protected by . . . Title VII . . . is indirect proof

of a causal connection between the firing and the activity because

it is strongly suggestive of retaliation." Oliver v. Digital Equip.

Corp., 846 F.2d 103, 110 (1st Cir. 1988).

           The   facts    demonstrate     sufficient   temporal        proximity

between the protected conduct and the employment action in this case

to make out a prima facie case.         On March 18, 1998, Calero received

the memorandum of admonishment, the first adverse employment action.

On April 21, 1998, Calero first contacted the EEO Office.                On May

11, 1998, Calero filed her first EEO complaint.             Calero sent Penca

a copy of this complaint, and Penca in turn, forwarded the complaint

to Reyes. We have noted that the prima facie burden in this context

is not an onerous one. Fennell v. First Step Designs, Ltd., 83 F.3d

526, 535-36 (1st Cir. 1996).            As plaintiff received her first

proposed suspension on June 22, 1998, roughly a month after she made

defendants aware that she filed her EEO complaint, we find plaintiff

has met her burden of making out a prima facie case of retaliation.

           Once the plaintiff has made a prima facie showing of


                                       -37-
retaliation, the McDonnell Douglas burden-shifting approach is

employed,    and   defendant    must   articulate   a   legitimate,   non-

retaliatory reason for its employment decision.         If the defendant

meets this burden, the plaintiff must now show that the proffered

legitimate reason is in fact a pretext and that the job action was

the result of the defendant's retaliatory animus.          See St. Mary's

Honor Ctr. v. Hicks, 509 U.S. 502, 510-11 (1993).           We have noted

the manner in which courts should consider the McDonnell Douglas

analysis in the context of summary judgment: "[O]n summary judgment,

the need to order the presentation of proof is largely obviated, and

a court may often dispense with strict attention to the burden-

shifting framework, focusing instead on whether the evidence as a

whole is sufficient to make out a question for a factfinder as to

pretext and discriminatory animus."        Fennell, 83 F.3d at 535.

            Defendants have, in fact, identified numerous clear,

specific reasons for the adverse employment actions taken against

Calero having nothing to do with any impulse to retaliate against

her for protected conduct.       The troubling history of plaintiff's

insubordinate and disruptive behavior and the occasions when she

failed to perform her duties in a satisfactory manner all provided

legitimate justification for disciplinary action entirely untainted

by retaliatory animus.         That plaintiff may point to this same

evidence in support of her Rehabilitation Act claim does not

diminish the significance of these shortcomings as legitimate bases


                                   -38-
for discipline.        The analytical matrix is different for the two

statutes, and evidence that may assist a plaintiff's case from one

vantage may damage it from another.           Since Calero has failed to

point to specific facts that would demonstrate any sham or pretext

intended to cover up defendants’ retaliatory motive, we will affirm

the dismissal of her retaliation claim under Title VII.

                               V. Conclusion

           The precedential value of this decision may be limited,

to some extent, by its unusual circumstances:         the confused state

of the record, plaintiff's pro se status, and the failure of

appellees' counsel to address in any way the central issues raised

by the appeal.    In any event, we are unable to say with confidence

that no reasonable factfinder, taking the facts from this record as

plaintiff might present them, could return a favorable verdict on

the Rehabilitation Act claim.        For this reason, we must conclude

that the district court's allowance of defendants' motion for

summary judgment on this count was in error. We therefore REVERSE

AND   VACATE     the     district   court's    judgment   regarding   the

Rehabilitation Act and REMAND for further proceedings consistent

with this opinion.        In all other respects, the judgment of the

district court is AFFIRMED.

          Costs are assessed against the appellees.




                                    -39-