Stanley Snead v. Florida Agricultural and Mechanical University Board of Trustees
17-10338
11th Cir.Feb 21, 2018Background
- Stanley Snead, a FAMU campus police officer (2005–2013), retired after the department switched from predominantly 8-hour shifts to 12-hour shifts in Aug. 2013 under a new chief.
- Snead developed hypertension related to 12-hour shifts; his cardiologist recommended return to daytime 8-hour shifts.
- FAMU refused the requested schedule accommodation; Snead retired and sued under the ADA for failure to provide a reasonable accommodation (constructive discharge).
- At trial the jury found for Snead, awarding lost wages/benefits and emotional damages; FAMU renewed a JMOL arguing Snead failed to prove essential functions, ability to perform, and reasonableness of the accommodation, and that the accommodation would cause undue hardship.
- The Eleventh Circuit reviewed denial of JMOL de novo and affirmed, concluding a reasonable jury could find Snead established each element and that FAMU failed to prove undue hardship.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 12-hour shifts were an "essential function" of Snead's job | Snead: Job description listed essential duties but did not list shift length as essential; working hours section allowed changes, so shift length is not essential | FAMU: Position description and testimony show 12-hour shifts are required; department needs officers on 12-hour schedule | Held: Jury could reasonably conclude shift length was not an essential function (issue goes to jury) |
| Whether Snead was a "qualified individual" able to perform essential functions with accommodation | Snead: Testified he could perform listed duties; cardiologist said he could perform job duties with restriction to daytime 8-hour shifts | FAMU: Snead's testimony was self-serving and unsupported | Held: Sufficient evidence (testimony + cardiologist letter) supported that Snead could perform essential functions with accommodation |
| Whether requested accommodation (revert to prior 8-hour daytime schedule) was reasonable | Snead: Physician letters and marked job description showed accommodation would allow performance of essential duties, including occasional overtime/special events | FAMU: The physician's restrictions should be read rigidly and would disrupt operations | Held: Jury could reasonably interpret the accommodation as consistent with prior duties and find it reasonable |
| Whether providing the accommodation would impose undue hardship on FAMU | FAMU: Chief testified multiple operational harms (loss of briefings, manpower gaps, overtime, supervisory/evaluation difficulties, equipment shortages) | Snead: Chief’s testimony included implausible claims about catastrophic departmental losses; jury could disbelieve hardship testimony | Held: FAMU failed to carry its burden; jury could reject the hardship evidence and find no undue hardship |
Key Cases Cited
- Pickett v. Tyson Fresh Meats, Inc., 420 F.3d 1272 (11th Cir. 2005) (standard for granting judgment as a matter of law)
- D’Angelo v. ConAgra Foods, Inc., 422 F.3d 1220 (11th Cir. 2005) (elements for ADA failure-to-accommodate claim)
- Holly v. Clairson Indus., L.L.C., 492 F.3d 1247 (11th Cir. 2007) (factors for determining essential functions and reasonableness of accommodation)
- Lucas v. W.W. Grainger, Inc., 257 F.3d 1249 (11th Cir. 2001) (plaintiff’s burden to identify accommodation and show it enables performance of essential functions)
- Willis v. Conopco, Inc., 108 F.3d 282 (11th Cir. 1997) (burden on defendant to prove undue hardship)