Equal Employment Opportunity Commission v. C.R. England, Inc.
644 F.3d 1028
| 10th Cir. | 2011Background
- Watson, HIV-positive, began as a driver for C.R. England in 2002 and became an independent contractor under ICOA in December 2002.
- Watson trained as a driver-trainer in Feb 2003; England discussed disclosing HIV status to trainees and drafted an HIV acknowledgment form.
- Watson’s trainee Eddie Seastrunk signed the form; no other trainees were shown the form; Watson’s HIV status was not disclosed to others by Watson's assent.
- Watson was terminated as trainer on Feb 14, 2003 for allegedly burning hours, refusing a load, and deadheading home; lease obligations continued.
- Watson later left Florida with the leased truck, ceased income, and England repossessed the truck; Watson later filed EEOC complaint alleging ADA violations.
- District court granted summary judgment for England on all claims; EEOC and Watson appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the HIV acknowledgment form unlawfully discriminate under ADA § 102(b)(1)? | Watson argues form limited opportunities due to disability. | England contends no adverse employment action occurred; form had no impact on opportunities. | No actionable adverse action; no discrimination under § 102(b)(1). |
| Did England’s disclosure of HIV status to a trainee violate ADA § 102(d)? | Disclosures violated confidentiality protections of § 102(d). | Disclosed information was voluntary; § 102(d) does not cover voluntary disclosures. | Voluntary disclosure not protected by § 102(d); no § 102(d) violation. |
| Did England fail to provide a reasonable accommodation by denying home time under ADA § 102(b)(5)? | Watson needed time off for medical treatment; accommodation required. | Watson did not adequately request a disability-related accommodation; notices were generic. | No reasonable accommodation trigger; § 102(b)(5) not violated. |
| Is Watson’s retaliation claim under the ADA viable due to debt collection actions? | Collection of debt after EEOC complaint constitutes retaliation. | No causal link; legitimate debt collection justified; no pretext shown. | Retaliation claim fails; no proximate causation or pretext shown. |
| Did termination as trainer/driver amount to ADA discrimination? | Terminations were motivated by disability. | Proffered reasons (hours, refusals, deadheading) are legitimate and not pretextual. | Termination claims fail; no pretext established; arguments insufficient to show discrimination. |
Key Cases Cited
- Sanchez v. Denver Pub. Schs., 164 F.3d 527 (10th Cir. 1998) (adverse action requires more than a mere inconvenience)
- Hillig v. Rumsfeld, 381 F.3d 1028 (10th Cir. 2004) (defines adverse employment action case-by-case)
- Doebele v. Sprint/United Mgmt. Co., 342 F.3d 1117 (10th Cir. 2003) (McDonnell Douglas framework in ADA discrimination)
- MacKenzie v. City & Cnty. of Denver, 414 F.3d 1266 (10th Cir. 2005) (prima facie analysis for discrimination cases)
- Zamora v. Elite Logistics, Inc., 478 F.3d 1160 (10th Cir. 2007) (pretext and burden-shifting in discrimination claims)
- Proctor v. United Parcel Serv., 502 F.3d 1200 (10th Cir. 2007) (causation and pretext in retaliation claims)
- Stover v. Martinez, 382 F.3d 1064 (10th Cir. 2004) (pretext sufficiency standard for discrimination)