Jackson v. City of Hot Springs, No. 13-1772 (8th Cir. 2014)
Annotate this CasePlaintiff filed suit against the city, alleging claims under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601; Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq.; section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 701; and the Arkansas Civil Rights Act (ACRA), Ark. Code 16-123-107. Both parties appealed the judgment of the district court. The court concluded that a reasonable juror could find that plaintiff could perform the essential functions of the job for which he interviewed and that plaintiff presented sufficient evidence to support an inference of a retaliatory motive on the part of the city. Accordingly, the court affirmed the district court's denial of the city's motion for judgment as a matter of law on the FMLA retaliation claim. The court affirmed the district court's grant of the city's motion for judgment as a matter of law on plaintiff's ACRA disability-discrimination claim where plaintiff introduced no evidence to demonstrate that the city knew about his conditions when he sought to be rehired; affirmed the district court's vacatur of the jury's award for emotional-distress where the ACRA claim submitted to the jury did not provide a basis for the jury's award of emotional-distress damages; and reversed the denial of liquidated damages because the city cited no evidence in support of the district court's finding that it acted in good faith in refusing to rehire plaintiff and the court could find none.
Court Description: Civil case - Employment discrimination. On plaintiff's claim for Family Medical Leave Act retaliation, viewing the evidence in the light most favorable to plaintiff, sufficient evidence supported the jury's finding that plaintiff was able to perform the essential function of the job for which he interviewed; plaintiff also presented sufficient evidence to support an inference of a retaliatory motive on the part of the defendant; no error in granting defendant judgment as a matter of law on plaintiff's Arkansas Civil Rights Act claims affirmed as plaintiff failed to put forth sufficient facts for a jury to conclude that defendant did not rehire him because of a disability; the Arkansas Civil Rights Act claim submitted to the jury did not provide a basis for the jury's award of emotional-distress damages, and the district court did not err in vacating that award; the district court abused its discretion when it denied plaintiff's claim for liquidated damages.
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