Gardea v. JBS USA, LLC, No. 17-2163 (8th Cir. 2019)
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The Eighth Circuit affirmed the district court's judgment in favor of JBS in an action under the Americans with Disabilities Act (ADA), the Iowa Civil Rights Act (ICRA), and the Iowa Wage Payment Collection Law (IWPCL). Plaintiff alleged a failure to accommodate claim and a termination claim, as well as a claim that JBS intentionally failed to pay plaintiff a portion of his earned wages.
The court held that, even if plaintiff was disabled, he was not qualified to perform the essential functions of his job, and his claims failed on that basis. The court explained that lifting was an essential function of the maintenance mechanic position that could not be reasonably accommodated, and plaintiff failed to show that accommodations JBS offered were unreasonable. The court held that plaintiff was not a qualified individual under the ADA and thus his termination claim also failed. Finally, because mere allegations were insufficient to rebut a properly supported motion for summary judgment, the district court properly granted summary judgment as to the IWPCL claim. In this case, JBS's payroll records reflected that plaintiff was correctly paid and any errors were quickly remedied.
Court Description: Magnuson, Author, with Loken and Erickson, Circuit Judges] Civil case - Americans with Disabilities Act. Even if plaintiff was disabled,he was not qualified to perform the essential functions of his mechanic's job, which included lifting; his request that he receive assistance from other mechanics was not a reasonable accommodation as it would require the defendant to extensively change its practices and work environment; additionally, the accommodation of a lift-assisting device was not feasible in the work environment and would impose an undue hardship on the operation of defendant's business; because the defendant offered plaintiff several jobs within his restrictions, and he failed to show that other, more comparable jobs were available, the district court was correct in holding defendant fairly engaged in the required interactive process and its attempts to accommodate plaintiff with other jobs were reasonable; with respect to plaintiff's claim that defendant terminated him by placing him on medical leave and terminating him 12 months later, his termination claim fails because he was not a qualified individual under the ADA; pay claim under Iowa law rejected as the record shows plaintiff was paid correctly.
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