4th Circuit lays out employer-friendly framework for ADA claims

The U.S. 4th Circuit Court of Appeals (whose rulings apply to all North Carolina, South Carolina, and West Virginia employers) recently issued a decision involving a former employee's disability discrimination claim that is expected to be welcomed by employers across the court's footprint. In concluding the employer "at multiple turns" met the Americans with Disabilities Act's (ADA) core obligation of providing reasonable accommodations to employees, the court put forth a framework that balances both disabled workers' needs and employers' legitimate interests.

Facts

Charles Elledge was the market director of stores for Lowe's. He oversaw 12 stores, conducting two store visits each day and working between 50 and 60 hours each week. His duties involved considerable walking and driving.

In December 2014, Elledge had knee surgery and was out of work for several months. When he returned from leave, his doctor ordered him to restrict his walking to no more than four hours each day and his workday to no more than eight. The medical restrictions prevented him from performing the full range of his job duties.

As a temporary accommodation, Lowe's agreed Elledge should abide by his doctor's orders and offered him the use of a motorized scooter during store visits. He declined the use of the scooter. Although he did comply with his light-work schedule most of the time, he arranged for lower-ranking colleagues to drive him to and from the stores he supervised, and he frequently disregarded the doctor's instructions to limit his work hours.