Labor & Employment – ‘Qualified Individual’ Under the ADA – Reasonable Accommodation

Defendant was not a “qualified individual” under the ADA because his medical restrictions prevented him from performing the essential functions of his job with or without reasonable accommodation.

We affirmed summary judgment for Defendant in full.

Plaintiff, a former rehang supervisor at a chicken-processing plant, brought an ADA suit against Defendant employer. Plaintiff had worked for Defendant since 2016 and was promoted to a salaried supervisory role in 2018. His job required extensive walking and standing, supervising multiple production lines, managing staff and paperwork, and operating in a cold, wet, noisy environment with machinery. He spent roughly 75–80% of his shifts on his feet and sometimes worked directly on the production line.

In August 2021, Plaintiff was seriously injured in a shooting unrelated to work, requiring surgeries and a lengthy recovery. He took FMLA leave and later attempted to return to work with significant medical restrictions, including seated work only, no use of his left arm, and strict limits on lifting, pushing, pulling, standing, and walking. After further medical evaluations, his doctor maintained these restrictions and added requirements for frequent rest and limits on standing and walking.

Defendant engaged in an interactive process with Plaintiff, reviewing the physical demands of his job and consulting with management and human resources. Ultimately, Defendant concluded that Plaintiff could not perform the essential functions of the rehang supervisor position with or without reasonable accommodation and that no vacant positions were available that fit his restrictions. After Plaintiff exhausted his leave, Defendant terminated his employment but told him he could reapply if his condition improved and pursue long-term disability benefits.

Plaintiff sued, alleging ADA wrongful termination, failure to accommodate, and a per se ADA violation based on an alleged “100% healed” return-to-work policy. The district court granted summary judgment for Defendant, holding that Plaintiff was not a “qualified individual” under the ADA because he could not perform the essential functions of his job, even with reasonable accommodation.

We emphasized that both wrongful termination and failure-to-accommodate claims require the plaintiff to be a “qualified individual,” meaning someone who can perform the essential job functions with or without accommodation. Comparing Plaintiff’s restrictions to the job’s physical demands, we found the record showed he could not meet those essential functions. Plaintiff’s own testimony confirmed he could not perform the required duties under his restrictions, which defeated his claims as a matter of law.

We also rejected Plaintiff’s per se ADA claim. We agreed with the district court that Defendant did not maintain a blanket “100% healed” policy; instead, the evidence showed Defendant had accommodated other employees and allowed returns to work with restrictions when those restrictions did not prevent performance of essential job functions. Here, Defendant’s decision was tied specifically to Plaintiff’s limitations and job requirements, not to any across-the-board policy.

Affirmed.

Robinson v. Mountaire Farms of North Carolina Corp. (Lawyers Weekly No. 001-038-26, 10 pp.) (Per Curiam) Appealed from the U.S. District Court for the Eastern District of North Carolina, at Wilmington (James C. Dever, III, J.) ON BRIEF: Ralph T. Bryant, Jr., RALPH BRYANT LAW FIRM, Greenville, North Carolina, for Appellant. J. Larry Stine, Elizabeth K. Dorminey, WIMBERLY, LAWSON, STECKEL, SCHNEIDER & STINE, P.C., Atlanta, Georgia, for Appellee. U.S. Court of Appeals for the Fourth Circuit Unpublished