Caraballo v. City of Jersey City Police Dep't
204 A.3d 254
| N.J. | 2019Background
- Frank Caraballo, a Jersey City police detective, was injured in a 1999 on-duty car accident and developed chronic knee injuries; physicians agreed he would likely need total knee replacements.
- Caraballo filed a workers' compensation claim in 2001, repeatedly sought authorization for bilateral knee replacement surgery from the city, but never sought enforcement in the workers' compensation court and ultimately retired in 2011 and settled his WC claim in 2013.
- After settlement, Caraballo sued the Jersey City Police Department under the New Jersey Law Against Discrimination (LAD), alleging failure to reasonably accommodate his disability by refusing to authorize knee surgery.
- The trial court granted summary judgment for the JCPD, finding (1) Caraballo failed to exhaust workers' compensation remedies and (2) medical treatment (knee surgery) is not a "reasonable accommodation" under the LAD; the court also found he was not qualified to perform essential job functions even with accommodation.
- The Appellate Division reversed, finding material factual disputes (including whether surgery would have enabled him to work) and concluding a prima facie LAD failure-to-accommodate claim could exist.
- The Supreme Court reversed the Appellate Division: it held Caraballo failed to exhaust the Act's administrative remedies and that medical treatment (knee surgery) does not constitute a reasonable accommodation under the LAD.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether an employee who pursued but did not enforce WC remedies may bring an LAD failure-to-accommodate claim based on denial of medical treatment | Caraballo: LAD claim valid because JCPD terminated/forced retirement without providing the reasonable accommodation of knee surgery | JCPD: Act is exclusive remedy; employee must exhaust WC enforcement mechanisms before pursuing LAD relief | Held: Employee who fails to utilize/enforce Act remedies cannot base an LAD failure-to-accommodate claim on the denial of WC-ordered medical benefits; exhaustion required |
| Whether medical treatment (total knee replacement) can be a "reasonable accommodation" under the LAD | Caraballo: Knee surgery would have been the reasonable accommodation enabling him to work | JCPD & amici: Medical treatment is not a workplace modification and thus not an accommodation; allowing it would circumvent WC exclusivity | Held: Medical treatment (knee surgery) is not a reasonable accommodation under the LAD |
| Whether Caraballo was qualified to perform essential job functions with or without the surgery | Caraballo: Disputed material facts exist as to whether surgery would have enabled him to perform duties | JCPD: Medical records show he could not safely perform essential functions even with surgery | Held: Court affirmed summary judgment on exhaustion and accommodation grounds; trial-court factual findings about qualifications unnecessary to the ultimate ruling |
| Whether WC statutory enforcement changes (post-Flick statutes) affect exclusivity analysis | Caraballo: Legislative/enforcement changes do not displace LAD remedies | JCPD: New enforcement mechanisms reinforce that WC remedies are the proper route; LAD claims cannot be used to bypass Act | Held: The Legislature’s creation of WC enforcement tools (N.J.S.A. 34:15-28.2) confirms employees must exhaust WC remedies before pursuing parallel LAD claims |
Key Cases Cited
- Stancil v. ACE USA, 211 N.J. 276 (2012) (explains Workers' Compensation Act exclusivity and rejects creating a new cause of action outside WC enforcement mechanisms)
- Flick v. PMA Ins. Co., 394 N.J. Super. 605 (App. Div. 2007) (employees must first pursue available WC remedies before filing in Law Division for enforcement)
- Victor v. State, 203 N.J. 383 (2010) (articulates LAD failure-to-accommodate prima facie elements)
- Desmond v. Yale-New Haven Hosp., 738 F. Supp. 2d 331 (D. Conn. 2010) (medical treatment is not a reasonable accommodation under the ADA)
- Royster v. State Police, 227 N.J. 482 (2017) (LAD requires reasonable accommodation; LAD interpreted alongside the ADA)