United States Equal Employment Opportunity Commission v. St. Joseph's Hospital, Inc.
842 F.3d 1333
11th Cir.2016Background
- Bryk, a long‑term psychiatric nurse, used a cane for gait dysfunction (spinal stenosis, hip replacement); hospital prohibited cane in psychiatric ward citing safety and offered reassignment options.
- Hospital waived normal internal-transfer restrictions and gave Bryk 30 days to identify and apply for other positions; she applied for seven jobs (three during final day, one after deadline).
- EEOC sued under the ADA alleging failure to reasonably accommodate by denying cane use and by not reassigning Bryk to vacant positions without requiring competition.
- At summary judgment the district court found Bryk disabled and that 30 days to apply was reasonable as a matter of law, but left factual issues about certain vacancies for trial; jury found failure to accommodate and also found hospital acted in good faith, ending deliberations and yielding judgment for the hospital.
- EEOC moved under Rule 59(e) arguing the good‑faith finding is only a damages defense; the district court granted relief, ordered opportunity for reinstatement, but the court of appeals reversed that alteration as an improper use of Rule 59(e).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Bryk is "disabled" under the ADA | Bryk’s gait dysfunction substantially limits walking; qualifies as disability | Hospital: pain alone insufficient | Held: Bryk was a disabled individual as a matter of law |
| Whether Bryk was a "qualified individual" for reassignment | Qualification judged as to desired positions, not current psychiatric post | Hospital: inability to perform current job without cane means not qualified | Held: Bryk was a qualified individual for the positions she sought |
| Whether ADA requires noncompetitive reassignment (priority over other applicants) | EEOC: ADA mandates reassignment without competition | Hospital: ADA does not require preferential reassignment; employer policies may control | Held: ADA does not mandate reassignment without competition; employers may require competition; Barnett framework applies |
| Whether 30 days to identify/apply for positions was reasonable | EEOC: jury should decide reasonableness of 30 days | Hospital: 30 days (extendable during active consideration) was reasonable as a matter of law | Held: 30 days was reasonable as a matter of law |
| Proper use of Rule 59(e) to alter judgment re: good‑faith defense | EEOC: good faith only bars compensatory/punitive damages under §1981a(a)(3); judgment should be altered to find liability and remand for damages/reinstatement | Hospital: EEOC invited instructions and verdict form treating good faith as dispositive; Rule 59(e) cannot be used to reverse its own litigation position | Held: District court abused discretion in granting Rule 59(e) relief; judgment for hospital reinstated |
Key Cases Cited
- U.S. Airways, Inc. v. Barnett, 535 U.S. 391 (Sup. Ct.) (framework for assessing reassignment claims that conflict with neutral employer rules)
- Terrell v. USAir, 132 F.3d 621 (11th Cir.) (ADA requires reasonable alternative opportunities in line with employer policies)
- Holly v. Clairson Indus., L.L.C., 492 F.3d 1247 (11th Cir.) (summary judgment standard in ADA cases)
- Mazzeo v. Color Resolutions Intern., LLC, 746 F.3d 1264 (11th Cir.) (ADA Amendments Act simplifies disability threshold analysis)
- Willis v. Conopco, Inc., 108 F.3d 282 (11th Cir.) (undue hardship is a complete defense to liability)