Bell v. O'Reilly Auto Enterprises, LLC, No. 18-2164 (1st Cir. 2020)Annotate this Case
The First Circuit vacated the judgment of the district court in favor of Defendant on Plaintiff's claim that Defendant failed properly to accommodate his disability under the Americans with Disabilities Act (ADA), 42 U.S.C. 1210 et seq., and the Maine Humans Rights Act (MHRA), Me. Rev. Stat. 5, 4551 et seq., holding that the district court committed prejudicial error in instructing the jury.
On appeal, Plaintiff argued that the district court erred in instructing the jury that to succeed on a claim that an employer failed to provide a reasonable accommodation, a plaintiff must prove that he needed an accommodation to perform the essential functions of his job. The First Circuit agreed, holding (1) by instructing the jury that an employee must demonstrate that he needed an accommodation to perform the essential functions of his job, the district court wrongly limited Plaintiff's potential liability; and (2) the error was prejudicial.