Terry Tyler v. La-Z-Boy Corporation, 506 F. App'x 265

Tyler, an upholsterer at La-Z-Boy's Newton, MS plant, injured his shoulder in 2005 and later worked with lifting restrictions.
He returned in 2006 to a lower-duty upholstery training position with restrictions; additional surgery occurred in 2007.
La-Z-Boy conducted large layoffs beginning in 2007; the upholstery department lost many jobs and the second/third shifts were eliminated.
Tyler was laid off on October 16, 2008, after the company could not find a position accommodating his lifting limits.
Tyler claimed age and disability discrimination under ADEA and ADA; district court granted summary judgment for La-Z-Boy.
The Fifth Circuit affirmed, holding lifting restrictions did not constitute a disability and the layoffs followed neutral, seniority-based criteria.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does lifting restriction amount to a disability under the ADA?	Tyler argues restrictions show a disability and/or being regarded as disabled.	La-Z-Boy contends lifting limits do not constitute a disability under the ADA.	No disability found; lifting limits not a substantial impairment.
Did La-Z-Boy regard Tyler as disabled?	La-Z-Boy treated him as disabled due to his limitations.	No misperceptions; company lacked positions to accommodate restrictions.	La-Z-Boy did not regard Tyler as disabled.
Did Tyler establish a prima facie case of ADA discrimination and rebut nondiscriminatory reasons?	Tyler asserts discrimination due to disability alongside layoff context.	Laying off during a broad RIF with neutral, seniority-based criteria was legitimate.	Disability claim fails; no triable issue on pretext given neutral, seniority-based RIF.
Did Tyler establish a prima facie case of age discrimination under the ADEA and rebut employer's reasons?	Tyler was older; his layoff coupled with retention of younger workers suggests discrimination.	RIF and seniority-based decisions were legitimate; no evidence younger, less qualified employees were preferentially treated.	No actionable age discrimination; legitimate nondiscriminatory reasons supported summary judgment.

Sherrod v. American Airlines, Inc., 132 F.3d 1112 (5th Cir. 1998) (lifting limitations not necessarily a disability)
Ray v. Glidden Co., 85 F.3d 227 (5th Cir. 1996) (minimal lifting restrictions not a substantial impairment)
Tex. Instruments Inc. v. E.E.O.C., 100 F.3d 1173 (5th Cir. 1996) (RIFs with neutral criteria are typically nondiscriminatory)
Carmona v. Southwest Airlines Co., 604 F.3d 848 (5th Cir. 2010) (unworthy credence where employer’s reasons lack corroboration)
McInnis v. Alamo Community College Dist., 207 F.3d 276 (5th Cir. 2000) (triable issue in disability discrimination context for single firing)