Boitnott v. Corning Inc.
669 F.3d 172
4th Cir.2012Background
- Boitnott sued Corning under the ADA alleging he is disabled due to an eight-hour work-day limitation and inability to work overtime/rotational shifts.
- Boitnott previously worked rotating twelve-hour shifts with day/night rotation.
- After medical issues (heart attack, leukemia) he sought to return only if limited to eight hours per day.
- Corning treated him as not disabled, contending he could work a normal forty-hour week.
- A new day-shift, eight-hour position with overtime was created in 2005, Boitnott applied for and obtained it, returning to work on September 5, 2005.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether inability to work overtime is a 'substantial limitation' under the ADA | Boitnott is substantially limited because he cannot work overtime. | Overtime restriction does not constitute a substantial limitation; he can work forty hours. | No; overtime restriction alone is not substantial. |
| Whether Boitnott’s ability to work forty hours defeats disability under Sutton framework | If impairment restricts overtime, he may be disabled. | Forty-hour capability defeats disability since overtime is not a major life activity limit. | Forty-hour work week with inability to overtime does not show substantial disability. |
| Whether there is evidence Boitnott’s impairment significantly restricted a class of jobs or broad range of jobs | Impairment may restrict job opportunities. | Record lacks evidence of a class-wide or broad-range impact. | Record shows no significant broad-range restriction. |
Key Cases Cited
- Toyota Motor Mfg. v. Williams, 534 U.S. 184 (Supreme Court 2002) (major life activity work analyzed for disability)
- Sutton v. United Airlines, Inc., 527 U.S. 471 (Supreme Court 1999) (defined substantial limitation framework for ADA the possibility of work)
- Taylor v. Nimock's Oil Co., 214 F.3d 957 (8th Cir. 2000) (inability to work overtime may not limit opportunities broadly)
- Kellogg v. Union Pac. R.R. Co., 233 F.3d 1083 (8th Cir. 2000) (overtime restriction alone not substantial)
- Berg v. Norand Corp., 169 F.3d 1140 (8th Cir. 1999) (no broad class impact from overtime limit)
- Tardie v. Rehab. Hosp., of Rhode Island, 168 F.3d 538 (1st Cir. 1999) (overtime limitation not substantial disability)
- Cotter v. Ajilon Servs., Inc., 287 F.3d 593 (6th Cir. 2002) (class-of-jobs/broad-range analysis applied)