Carris James v. Hyatt Regency Chica
707 F.3d 775
7th Cir.2013Background
- James, Hyatt banquet steward since 1985, suffered a non-work eye injury and took an absence in 2007.
- Hyatt granted 12 weeks of FMLA leave; James later submitted multiple doctor notes and disability paperwork claiming incapacity.
- April 2007 doctor note allowed return to light duty on May 10, 2007; later notes claimed ongoing total incapacity, with disability benefits.
- Hyatt sought medical clarification and consistently attempted to determine James's true capabilities; James provided conflicting releases.
- James ultimately returned to work February 2008 after Dr. Scott limited vision to 20/200; James sued in 2009 seeking FMLA/ADA relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| FMLA interference element viability | James argues Hyatt denied FMLA benefits by delaying reinstatement after light-duty release. | Hyatt did not violate FMLA; no failure to reinstate given light-duty status and later full leave actions. | Hyatt did not interfere with FMLA benefits. |
| FMLA retaliation claim viability | James contends Hyatt retaliated by delaying return after FMLA requests. | No materially adverse action; multiple reinvitation attempts to return; decisions were not retaliatory. | No FMLA retaliation found. |
| ADA failure to accommodate claim viability | Hyatt failed to accommodate vision-related disability by not returning him with prior accommodations. | Employer did not receive clear disability notification; accommodations pursued once clarified; no failure to accommodate shown. | No evidence of failure to accommodate. |
| Discovery sanctions and denial of motions to compel | James argues discovery denials and sanctions were improper and prejudicial. | District court acted within discretion; requests were overbroad and unresponsive; sanctions reasonable. | No abuse of discretion; sanctions affirmed. |
Key Cases Cited
- Brumbalough v. Camelot, 427 F.3d 996 (6th Cir. 2005) (employer must reinstate when a doctor indicates return to work)
- Hendricks v. Compass Group, USA, Inc., 496 F.3d 803 (7th Cir. 2007) (no FMLA 'light duty' concept; light duty not required)
- Daugherty v. Wabash Center Inc., 577 F.3d 747 (7th Cir. 2009) (materially adverse action standard for retaliation)
- Nagle v. Village of Calumet Park, 554 F.3d 1106 (7th Cir. 2009) (materially adverse actions defined for retaliation)
- Crady v. Liberty Nat'l Bank & Trust Co., 993 F.2d 132 (7th Cir. 1993) (definitions of material adverse actions)
- Beck v. Univ. of Wis. Bd. of Regents, 75 F.3d 1130 (7th Cir. 1996) (employer liability triggered by disability notification)
- Miller v. Ill. Dep't of Transp., 643 F.3d 190 (7th Cir. 2011) (reasonable accommodation and task reassignment limits)
- Coleman v. Donahue, 667 F.3d 835 (7th Cir. 2012) (McDonnell Douglas burden in retaliation analysis)