John Goodpaster v. Schwan's Home Service, Inc. and Todd Swanson, Individually and in His Corporate Capacity
849 N.W.2d 1
| Iowa | 2014Background
- Goodpaster worked as a customer service manager for Schwan’s Home Service, requiring DOT compliance and a commercial driver's license.
- He was diagnosed with multiple sclerosis (MS) and experienced episodic flare-ups causing vision impairment and limb weakness.
- During flare-ups, he requested route rearrangements, backup drivers, or a warehouse transfer; some accommodations were denied.
- Sales and performance declined, and Goodpaster was terminated after warnings for failing to meet quotas.
- The district court granted summary judgment to Schwan’s; Goodpaster appealed arguing MS is a protected disability under the ICRA.
- The Iowa Supreme Court held MS can be a disability under the ICRA if episodic symptoms substantially limit major life activities.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is MS a disability under the ICRA? | Goodpaster is disabled during flare-ups | MS is not a substantial disability under ICRA | MS can be a disability if episodic symptoms substantially limit activities |
| Was Goodpaster qualified to perform essential functions with/without accommodation? | Can perform essential functions with accommodations | Cannot perform essential functions due to driving requirement | Material fact issue on qualification with/without accommodation |
| Did the termination evidence indicate unlawful discrimination? | Termination tied to MS concerns | Termination due to poor sales/performance | Record supports jury issue on discriminatory motive |
Key Cases Cited
- Albertson's, Inc. v. Kirkingburg, 527 U.S. 555 (Supreme Court 1999) (DOT safety standards may limit ADA applicability)
- Toyota Motor Mfg., Kentucky, Inc. v. Williams, 534 U.S. 184 (Supreme Court 2002) (strict interpretation of substantial limitation in ADA era)
- Sutton v. United Air Lines, Inc., 527 U.S. 471 (Supreme Court 1999) (requirement to consider corrective measures in disability analysis)
- Nyrop v. Indep. Sch. Dist. No. 11, 616 F.3d 728 (8th Cir. 2010) (ADA standards influencing disability analysis)
- Consolidated Freightways, Inc. v. Cedar Rapids Civil Rights Comm’n, 366 N.W.2d 522 (Iowa 1985) (disability can be arrested by sobriety; permanent vs intermittent)