On March 15, 1999 a panel of the First Circuit Court of Appeals upheld a judgment of the Federal District Court in Bangor, Maine awarding a process operator at a Houlton starch processing plant more than $300,000 on account of her discharge from employment in violation of the American with Disability Act (ADA)(Quint v. Staley Manufacturing Co.). The First Circuit Court of Appeals is in Boston and is the governing appellate court for all federal decisions issuing from Maine.
The Facts in Quint
Jacqueline Quint showed symptoms of mild carpal tunnel syndrome during the time of her employment as a process operator with A.E. Staley Manufacturing Company in Houlton. Ms. Quint had been hired in December of 1991. In 1993 and thereafter, Ms. Quint filed in excess of 25 petitions for award with the Workers' Compensation Board; all were successfully defended. In 1994 Staley terminated her employment after she failed to appear for an appointment with a doctor designated by Staley and then failed to appear for an appointment with the Staley plant manager to explain her reasons for missing the doctor's appointment. Ms. Quint filed an ADA claim in federal court alleging she was discharged from employment on account of her carpal tunnel syndrome, an irritated ulnar nerve condition, and an arm/shoulder syndrome.
In 1998 in Bangor Federal District Court a jury found Ms. Quint had been discharged on account of her disability and not because of her insubordination in refusing to appear for an appointment with the plant manager. The decision was appealed to the First Circuit Court of Appeals by Rudman & Winchell on behalf of Staley.
Noteworthy Rulings by the Appellate Court
In reviewing the Quint decision on appeal, the First Circuit made the following noteworthy rulings with respect to the ADA:
The employee was not required to submit the dispute to arbitration under the terms of an applicable union bargaining agreement because the agreement did not explicitly refer to ADA claims in the contract language requiring arbitration of employment disputes.
Bilateral carpal syndrome, even as mild as that experienced by Ms. Quint, can be a "disability" as the term is defined by the ADA. The Court decided that the employee had presented adequate evidence to meet the definition of "disability." Under the ADA a "disability" is defined in part as a physical or mental impairment that substantially limits one or more of a person's major life activities.
The First Circuit panel upheld a finding in favor of the employer reducing the employee's entitlement to back pay from $125,580 to $45,917 because the employee failed to seek suitable alternative employment after her discharge. She was awarded $45,917 for 18 months lost wages after her discharge but no further back pay was allowed because of her lack of any work search effort. The court agreed with the employer that when a plaintiff makes no effort to find other work, the employer does not have to prove that substantially equivalent work was available if plaintiff had looked.
The appellate court panel determined that the Federal District Court erred by authorizing a further reduction of back pay award on account of disability insurance proceeds and AFDC and food stamp benefits received by Ms. Quint.
The jury in the trial court awarded the employee $300,000 in compensatory damages and $420,000 in punitive damages. The trial court reduced the two awards to a total of $300,000 on account of the damages cap contained in the ADA. The First Circuit upheld the award against a challenge by the employer that even the capped award of $300,000 was excessive. The Court noted that a lack of adequate notice of a medical appointment made by the employer for an employee could constitute "reckless indifference" to the plaintiff's rights and could provide a basis for a jury to award punitive damages.
The First Circuit Court of Appeals remanded the case to the Federal District Court in Bangor for further consideration of the employee's right to reinstatement. The District Court had ruled that reinstatement would be impracticable because there were no available "light-duty" jobs Ms. Quint could perform and that the "tension" between Ms. Quint and her former co-workers would create an intolerable work environment. The case remains active on the question of reinstatement and related reasonable accommodation issues.
Conclusion
The interplay between Workers' Compensation rights and ADA claims is fertile ground for the birth of troublesome and difficult problems for human resource managers. Even employers with innocent and appropriate motives for employment actions can be found liable and responsible for substantial damage awards because a jury may be permitted to infer the existence of reckless and illegal motives on the part of the employer. With the advent of a myriad of new employment discrimination laws, an employer considering termination of an employee must review not only its own motivations but all possible interpretations of its motivations by others.