Tuesday, January 4, 2011

7th Circuit Rules Medical Evidence Not Necessary in Disability Discrimination Claim

The Court of Appeals for the Seventh Circuit delivered quite the present to plaintiff's attorneys this year in its ruling in Equal Employment Opportunity Commission v. Autozone, Inc., No. 10-1353. The EEOC alleged that AutoZone violated the Americans with Disabilities Act (ADA) in three ways: first, by failing to accommodate the plaintiff's physical limitations from March 2003 until September 2003; second, by discriminatorily denying the plaintiff the opportunity to work after September 2003; and third, by terminating him in retaliation for filing charges against the company. The district court granted summary judgment for AutoZone on the first claim, finding that the EEOC had not shown that the plaintiff had a disability within the meaning of the ADA as is required to demonstrate a failure to accommodate. A jury later ruled in favor of AutoZone on the discriminatory treatment and retaliation claims. The district court then denied the EEOC's motion to alter the judgment and for a partial new trial.

On appeal, the 7th Circuit had to decide whether the EEOC was required to present medical testimony to prove that the plaintiff was disabled within the meaning of the statute. They held that medical evidence was not necessary and precedent supports that conclusion. The court's analysis is quite in depth and shows that the plaintiff clearly presented enough evidence, without having to produce "medical evidence," that he was disabled within the meaning of the term in the ADA. The court also distinguished precedent Autozone attempted to use where medical evidence was required and showed that in those cases the plaintiff hadn't provided enough non-medical evidence to support an ADA claim.

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