Georgia Poultry Farm Granted Summary Judgment in Legally Blind Job Applicant’s ADA Suit

The Americans with Disabilities Act was enacted with the purpose of ending discrimination against individuals with disabilities by making it unlawful for employers to discriminate against a qualified individual on the basis of disability.

In order to assert a claim under the Act, a plaintiff must be able to prove that he or she is disabled, is a qualified individual, and was subjected to unlawful discrimination due to his or her disability.

If you believe that you have a claim under the Act, you should talk to an Atlanta disability discrimination attorney about filing a claim. There are time limits in such cases, and it is important that you assert your legal rights in a timely fashion.

Facts of the Case

The plaintiff, in a recent case, was a visually impaired man who worked for the defendant poultry farm intermittently from 1998 to 2001. He applied for work again in 2016 and was given a conditional offer of employment. His vision had reportedly worsened considerably since his previous period of employment with the defendant, however, and, after receiving documentation from the plaintiff’s medical provider concerning his limitations due to his vision issues, the defendant refused to hire the plaintiff. The plaintiff filed suit in federal court, asserting a claim under Title I of the Americans with Disabilities Act of 1990, as amended by the ADA Amendment Act of 2008, 42 U.S.C. ยง12101 et seq., challenging both the defendant’s refusal to hire him and its failure to engage in an interactive process to attempt to determine and provide reasonable accommodation for him.

The defendant filed a motion for summary judgment, asserting that the plaintiff, who was considered “legally blind” due to his visual acuity of 20/600, could not show that he was a “qualified individual” under the Act. The defendant further asserted that it was entitled to summary judgment on the issue of damages pursuant to the after-acquired evidence defense.

The District Court’s Decision

The United States District Court for the Southern District of Georgia, Statesboro Division, granted summary judgment to the defendant on the plaintiff’s claim under the Act. The court began its analysis by acknowledging that the parties were in apparent agreement as to the fact that the plaintiff had or was perceived to have a disability at the time of his 2016 job application and that the defendant was a covered entity under the Act. In the court’s opinion, the real dispute was whether the plaintiff was a “qualified individual” under the Act. In order to be granted relief under the applicable statute, an individual must be able to perform the essential functions of the employment position that he or she is seeking, either with or without reasonable accommodation.

After reviewing the evidence, the court found that the essential functions of the job sought by the plaintiff included weighing, measuring and mixing seasoning and ingredients, operating machinery, and monitoring the operation of the machinery. In the court’s opinion, the plaintiff had failed to make a prima facie showing that, considering his substantial visual impairment, he could perform the essential functions of the job either with or without reasonable accommodations. In so holding, the court noted that the plaintiff’s eye doctor had specifically said that the plaintiff “could not work with machinery and equipment” or “do tasks requiring ‘good vision.'”

In light of its ruling on the summary judgment motion, the court declined to rule on the defendant’s after-acquired evidence defense.

Speak to an Atlanta Employment Litigation Lawyer

To learn more about how you can assert your legal rights following an incident of disability discrimination, please call the experienced Atlanta disability discrimination attorneys of Parks, Chesin & Walbert at 877-986-5529. Our phone lines are open 24/7, and we handle a wide variety of employment law cases throughout the greater Atlanta area.