RRD Obtains Summary Judgment in ADA Case

RRD partner Beck Fineman obtained summary judgment on behalf of Metro-North Commuter Railroad Company in a case brought under the Americans with Disabilities Act.  In its decision dated March 12, 2014, the United States District Court found that neither Metro-North’s actions with respect to the plaintiff in this case, nor its practices overall, violated the ADA.

The plaintiff claimed that Metro-North discriminated against him by failing to promote him because it regarded him as disabled as a result of a work-related injury four years earlier.  Following that injury and a resulting nine-month absence, the plaintiff had returned to work without medical restrictions and had even been promoted to a management position, which he voluntarily left to return to a non-management position.  When the plaintiff subsequently applied for a “special duty” assignment, Metro-North considered his employment record with the company, including his safety record, which contained information regarding the prior injury, and denied him the position.  The plaintiff sued Metro-North under the ADA after being turned down for the special duty assignment, alleging that he was turned down because Metro-North regarded him as disabled.

RRD argued that Metro-North’s consideration of the plaintiff’s safety record and prior injuries with the company was not the same as considering his physical abilities, and that the ADA seeks to protect individuals with physical limitations, or who are perceived as having physical limitations, against discriminatory actions taken in response to those actual or perceived limitations.  The court agreed that this was not such a case, held that the plaintiff was not “disabled” within the meaning of the statute, and dismissed the plaintiff’s complaint in its entirety.