Hamilton v. Ortho Clinical Diagnostics
4:12-cv-00670
| E.D. Ark. | Jul 2, 2014Background
- Hamilton, a 40-year field engineer for Ortho Clinical, injured his back at work in May 2011 and took FMLA and disability leave; job required routine lifting up to 25 lbs and occasionally up to 50 lbs per company materials.
- Dr. Wayne Bruffett cleared Hamilton in October 2011 to return with permanent medium restrictions (occasional lifting 21–50 lbs; frequent 11–25 lbs). Hamilton provided the doctor’s notes to Occupational Health.
- Management concluded in late 2011 that Hamilton’s 50-lb restriction could not be accommodated, and his employment was terminated effective January 10, 2012. Hamilton disputes the adequacy of return-to-work discussions and that he could not lift 50 lbs.
- Hamilton filed EEOC charge February 2012 and sued under the ADA, ADEA, FMLA, and Arkansas Civil Rights Act; Ortho later reinstated him in August 2013 and offered back pay, which Hamilton declined.
- The district court denied summary judgment on Hamilton’s ADA/ACRA wrongful-discharge claim (finding direct evidence that termination was based on the lifting restriction under the ADA amendments), granted summary judgment for defendant on retaliation/FMLA/ADEA claims, and allowed a jury to decide Ortho’s direct-threat defense and wrongful-discharge liability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether termination was retaliation/discrimination for exercising FMLA/leave rights | Hamilton argues close temporal sequence and employer animus after leave | Ortho says time gap and no evidence of retaliatory motive; termination months after leave | Court: No causal link — summary judgment for Ortho on FMLA/retaliation claims |
| Whether age was a but-for cause of termination (ADEA) | Hamilton contends age motivated firing | Ortho denies age motive; no supporting evidence | Court: Hamilton failed to show age as but-for cause — summary judgment for Ortho |
| Whether Ortho failed to accommodate / disability claim under ADA (major-life-activity test) | Hamilton contends his lifting restriction required accommodation | Ortho contends restriction does not substantially limit a major life activity | Court: Hamilton failed to make prima facie failure-to-accommodate claim (no substantial limitation) — dismissed |
| Whether termination was wrongful discharge based on disability under ADA (post-2008 amendment) | Hamilton points to employer memos citing inability to lift 50 lbs as reason for firing | Ortho offers contested factual defenses including direct-threat and disputes essential function | Court: Evidence constitutes direct evidence of discrimination under 2008 ADA amendments; wrongful-discharge claim survives summary judgment; direct-threat defense raises jury question |
Key Cases Cited
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard and burden allocation)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for discrimination claims)
- Brown v. City of Jacksonville, 711 F.3d 883 (application of ADA post-2008 amendments)
- Libel v. Adventure Lands of Am., Inc., 482 F.3d 1028 (direct-evidence standard for discriminatory animus)
- Fiedler v. Indianhead Truck Line, Inc., 670 F.2d 806 (employee's duty to mitigate and back-pay remedy despite rejecting employer’s prior offer)