Charles Elledge v. Lowe's Home Centers, LLC
979 F.3d 1004
| 4th Cir. | 2020Background
- Chuck Elledge was a long‑time Lowe’s Market Director of Stores (MDS) who, after multiple knee surgeries, returned to work with doctor‑imposed limits (≤4 hours walking/day; ≤8 hours work/day).
- Lowe’s provided temporary accommodations: a light‑duty/40‑hour schedule and offer of an in‑store motorized scooter; Elledge declined to try the scooter and admitted he exceeded restrictions sometimes.
- Lowe’s concluded Elledge could not meet the MDS essential functions (frequent walking, travel to ~12 stores, and working >8 hours/day), extended temporary accommodations, then moved toward other roles and severance when restrictions persisted.
- Elledge applied for two other director positions (Lawn & Garden and Outdoor Power Equipment), was not selected under Lowe’s best‑qualified/succession procedures, and accepted a severance/early retirement.
- Elledge sued under the ADA (failure to accommodate; failure to reassign) and ADEA; the district court granted summary judgment for Lowe’s; the Fourth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Elledge was a “qualified individual” under the ADA able to perform essential functions with or without reasonable accommodation | Elledge: light‑duty schedule and scooter would let him perform essential MDS duties | Lowe’s: MDS essential functions include extended walking, travel, and >8‑hour days; Elledge’s permanent restrictions prevent performance | Court: Essential functions include walking, travel, and long hours; Elledge not qualified because restrictions precluded performance even with offered accommodations |
| Whether Lowe’s provided reasonable accommodations and whether it was required to provide the accommodations Elledge preferred | Elledge: Lowe’s accommodations were inadequate; Lowe’s should have kept him in MDS or provided preferred accommodation | Lowe’s: It offered reasonable accommodations, had discretion to choose among reasonable options, and Elledge rejected the scooter or did not comply with restrictions | Court: Lowe’s accommodations were reasonable; employer has ultimate discretion among reasonable accommodations and need not supply an accommodation the employee rejects |
| Whether Lowe’s violated the ADA by failing to reassign Elledge to vacant comparable director positions | Elledge: Barnett requires reassignment when accommodation fails; Lowe’s best‑qualified system does not justify refusing reassignment | Lowe’s: Reassignment is a last‑resort accommodation; its disability‑neutral best‑qualified/succession hiring system is reasonable and protects settled expectations | Court: Reassignment is last resort; in the run of cases employers need not reassign in contravention of reasonable, neutral hiring systems; Lowe’s conduct was reasonable and did not violate the ADA |
| Whether Lowe’s violated the ADEA by removing Elledge and rejecting his applications | Elledge: Younger applicants were favored despite being less qualified | Lowe’s: Elledge could not show he was qualified for MDS or that hires were pretextual; selected candidates had legitimate, superior qualifications | Court: ADEA claims fail—Elledge could not make prima facie showing of qualification for removal, and hiring decisions were non‑discriminatory |
Key Cases Cited
- U.S. Airways, Inc. v. Barnett, 535 U.S. 391 (2002) (reassignment is a last‑resort accommodation; neutral seniority or hiring systems may trump reassignment requests)
- Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (2000) (standard for reviewing adverse‑employment claims at summary judgment)
- Rohan v. Network Presentations LLC, 375 F.3d 266 (4th Cir. 2004) (definition and analysis of essential job functions)
- Tyndall v. Nat’l Educ. Ctrs., Inc. of Cal., 31 F.3d 209 (4th Cir. 1994) (essential functions and ADA framework)
- Reyazuddin v. Montgomery County Md., 789 F.3d 407 (4th Cir. 2015) (employer has discretion to choose among reasonable accommodations)
- EEOC v. St. Joseph’s Hosp., Inc., 842 F.3d 1333 (11th Cir. 2016) (reassignment and reasonableness of employer hiring policies)
- Huber v. Wal‑Mart Stores, Inc., 486 F.3d 480 (8th Cir. 2007) (best‑qualified hiring systems may preclude reassignment)
- Rodal v. Anesthesia Group of Onondaga, P.C., 369 F.3d 113 (2d Cir. 2004) (employer testimony and actual job duties in assessing essential functions)
- D’Angelo v. ConAgra Foods, Inc., 422 F.3d 1220 (11th Cir. 2005) (evidence relevant to employer’s judgment on essential functions)