Daughtry v. Army Fleet Support LLC, 1:11-cv-00153

Daughtry sued Army Fleet Support, alleging ADA violations after a shoulder injury affected accommodation.
Plaintiff, an aircraft mechanic, sought to continue in a parts-turn-in role, limited by seniority and union constraints.
Defendants argued no available parts-turn-in position for Daughtry’s seniority; creating or displacing others was not required by the ADA.
The district court granted summary judgment for defendants on all ADA claims, concluding no viable accommodation existed.
Daughtry moved under Rule 59(e) to alter, amend, or vacate the judgment, arguing manifest error and unfair handling.
The court denied the Rule 59(e) motion, noting no newly discovered evidence or manifest error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 59(e) relief was appropriate.	Daughtry seeks reconsideration to avoid manifest injustice.	Rule 59(e) is improper for rearguing settled issues without new evidence.	Denied; Rule 59(e) requires new evidence or manifest error.
Whether there was manifest error of law or fact in denying ADA accommodation.	There were available parts-turn-in positions for his seniority.	No available parts-turn-in position consistent with seniority; accommodation not required.	No manifest error; lack of viable accommodation remained.
Whether Army Fleet's handling of accommodation requests showed bad faith.	Procedural irregularities imply bad faith in seeking accommodation.	Irregularities do not prove a reasonable accommodation existed; need actual accommodation.	No manifest error; bad faith allegations insufficient.

Arthur v. King, 500 F.3d 1335 (11th Cir. 2007) (Rule 59(e) grounds require newly discovered evidence or manifest errors)
In re Yulin Ma, 346 F. App'x 436 (11th Cir. 2009) (cannot relitigate old matters or raise new arguments after judgment)
Hutchinson v. Staton, 994 F.2d 1076 (4th Cir. 1993) (mere disagreement with outcome does not support Rule 59(e) relief)