1st Circuit explores reasonable accommodations in Maine case

The Boston-based U.S. 1st Circuit Court of Appeals (which covers Maine, Massachusetts, New Hamshire, and Rhode Island employers) recently reversed a lower court's dismissal of an auto parts store employee's disability discrimination claim. The employee alleged the employer failed to accommodate his disabilities under the Americans with Disabilities Act (ADA) and the Maine Human Rights Act (MHRA). The case went to trial, and the jury found for the employer. But the employee's lawyer claimed the judge gave incorrect instructions on the law to the jury. The appeals court agreed and clarified the circumstances when a reasonable accommodation should be granted.

Facts

Brian Bell was the store manager of the O'Reilly Auto Parts store in Belfast, Maine, overseeing a team of eight to 12 employees. He managed the store's operations, including sales, profitability, and appearance. He typically worked 50 hours per week.

Bell is disabled—he has Tourette's syndrome, ADHD, and major depression. After two shift leaders left the business, he was unable to schedule employees for overtime and resorted to working the hours himself, logging almost 100 hours per week. His symptoms increased, and his mental health began to deteriorate.

On one occasion, Bell felt particularly stressed and decided to take a break in his car parked outside. His supervisor instructed him to return to work. Soon after, Bell visited his mental health provider to discuss his symptoms.