Benjamin Reynolds v. American National Red Cross
701 F.3d 143
| 4th Cir. | 2012Background
- Reynolds worked for the Greenbrier Valley Chapter of the American Red Cross from 2006 as Manager of Service Delivery; he was terminated for budgetary reasons in January 2007.
- Medical evidence centered on a 15-pound lifting restriction imposed by Dr. Mistry after a back/neck injury from moving a piano; Reynolds nonetheless lifted objects beyond the restriction at times.
- Reynolds claimed ADA discrimination, retaliation for protected activity, and confidentiality violations; the EEOC later concluded the Chapter was not an ADA-covered employer.
- The district court granted summary judgment on disability and confidentiality claims but held the Chapter could be an ADA employer via agency theory; cross-appeal challenged the employer-aggregation rule.
- Reynolds pursued discovery and briefing in district court; on appeal the Fourth Circuit addressed disability status, retroactivity, retaliation, confidentiality, and employer aggregation, issuing a mixed ruling affirming some parts, vacating others, and dismissing the cross-appeal.
- The final disposition: the district court’s summary judgment in favor of Appellees is affirmed on the ADA merits, the Chapter-as-employer ruling is vacated, and the cross-appeal is dismissed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Reynolds is a qualified individual with a disability under the ADA. | Reynolds contends he has a disability based on back/neck impairment. | Appellees argue Reynolds failed to prove a disability under pre-ADAAA definitions. | Reynolds failed to show a disability under all ADA definitions. |
| Whether the ADA Amendments Act of 2008 applies retroactively to conduct in 2006-2007. | ADAAA should apply because it broadens disability interpretation. | ADAAA does not apply retroactively; retroactivity requires clear statutory language. | ADAAA does not apply retroactively; pre-ADAAA standards control. |
| Whether Reynolds’ retaliation claim is viable. | Termination followed protected conduct (lifting-limit request/workers’ comp inquiry). | No ADA violation or valid protected activity linkage under the record; workers’ comp retaliation not covered by ADA. | Retaliation claim fails. |
| Whether the Chapter is an “employer” under the ADA and whether its and the National Red Cross’s employees can be aggregated. | Aggregation should reach 15+ employees for liability. | Aggregation is appropriate and Chapter could be liable as an ADA employer. | Cross-appeal dismissed; the aggregation issue is moot; district court’s employer finding vacated. |
Key Cases Cited
- Toyota Motor Mfg., Ky., Inc. v. Williams, 534 U.S. 184 (Sup. Ct. 2002) (defined 'substantially limits' a major life activity under pre-ADAAA ADA standards)
- Sutton v. United Air Lines, Inc., 527 U.S. 471 (Sup. Ct. 1999) (set stringent interpretation of 'substantially limits' prior to ADAAA)
- Landgraf v. U.S. Film Prods., 511 U.S. 244 (Sup. Ct. 1994) (presumption against retroactivity; governs retroactive application of statutes)
- Arbaugh v. Y & H Corp., 546 U.S. 500 (Sup. Ct. 2006) (employer threshold under ADA treated as an element of the claim, not jurisdictional)
- Williams v. Channel Master Satellite Sys., Inc., 101 F.3d 346 (4th Cir. 1996) (lifting limitation alone not necessarily a disability under ADA (pre-ADAAA))