By: Loyd Willaford and Mathias Deeg
In Easter v. Alabama Department of Youth Services, the U.S. District Court for the Northern District of Alabama held that a jury could find that Alabama Department of Youth Services’ stated reasons for the demotion of a disabled shift supervisor were not convincing, suggesting that the Department discriminated against the supervisor.
David Easter was a shift supervisor at the Birmingham campus of the State of Alabama Department of Youth Services. He sued the Department for unlawful discrimination after being demoted following his release of medical information about his Sarcoidosis-related enlarged spleen. Easter had regularly been medically excused from annual trainings as a precaution for his condition. He had engaged in “refresher” trainings to compensate for his absence. Following the 2010 annual trainings, the Department requested additional information from all employees medically excused from participating. In response to Easter’s information, the Department held a fact-finding hearing to determine his ability to perform his job. On the same day as the hearing, the Department demoted Easter with a corresponding decrease in pay.
Easter claimed the Department perceived his condition as disabling and demoted him in violation of the Americans with Disabilities Act and the Rehabilitation Act. He argued that his employment history gave no indication of unsatisfactory work, and that his excuse from parts of the annual training did not impede his ability to perform his duties because (1) he always completed “refresher” training and (2) the training exercises involved physical conduct he would never be subjected to in his job. Easter held that the timing of his demotion, along with his positive work history, implied discriminatory intent on the part of the Department.
The Department argued that Easter was not discriminated against because the decision to demote him was made long before his condition became known. Easter’s supervisor claimed that the decision to demote Easter was made years before for poor performance, and that it was only during the hearing that they realized Easter was still a shift supervisor. Furthermore, the Department claimed that Easter’s inability to complete the training disqualified him from his shift-supervisor role.
The court held that, in the light of conflicting facts, the Department’s reasons for demoting Easter were shaky at best. Easter successfully showed that there were
such weaknesses, implausibilities, inconsistencies, incoherencies, or contradictions in [the Department’s] proffered legitimate reasons for its action that a reasonable fact finder could find them unworthy of credence.
The Department claimed that the decision to demote Easter was made long before his hearing, but the court found that the first evidence of a decision to demote Easter came following the hearing. Furthermore, the Department’s claim that Easter had a record of poor performance before demotion was contradicted by historically positive performance evaluations. Finally, the Department’s assertion that Easter’s absence from annual training disqualified him from his duties was unconvincing because there were serious questions as to the necessity and value of the training and make-up trainings were routinely given.
This case demonstrates the importance of digging for documents related to an employer’s reasons for taking an employment action. Easter got his case to a jury by showing the reasons the Department gave for his demotion were contradicted by their own records.
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