Rehrs v. IAMS Co.
486 F.3d 353 (2007)
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Rule of Law:
A uniformly applied job requirement, such as a rotating shift schedule, constitutes an essential function of a position under the Americans with Disabilities Act (ADA) if the employer provides legitimate, non-discriminatory business reasons for it. An employee unable to meet such a requirement is not considered a 'qualified individual' for that position.
Facts:
- Murray Rehrs, who has Type I diabetes, worked as a warehouse technician for the Iams Company from 1997.
- In 1999, Procter and Gamble, Inc. (P & G) acquired Iams and, in January 2000, implemented a mandatory rotating 12-hour shift schedule for all warehouse technicians.
- Rehrs worked the rotating shift schedule from January 2000 until February 2002, when he had a heart attack.
- After returning to work, Rehrs's doctor submitted a letter in September 2003 requesting that Rehrs be placed on a permanent fixed daytime schedule to help control his diabetes.
- P & G granted Rehrs a temporary 60-day accommodation to work a fixed shift but refused to make it permanent, asserting that shift rotation was an essential function of the warehouse technician position.
- P & G offered Rehrs a temporary fixed-shift sanitation position, which he declined.
- P & G also notified Rehrs of other vacant fixed-schedule jobs, but he was either unqualified for or uninterested in them.
- Rehrs subsequently went on partial and then total disability leave.
Procedural Posture:
- Murray Rehrs filed a lawsuit against Procter and Gamble, Inc. in the U.S. District Court for the District of Nebraska, alleging disability discrimination under the ADA and NFEPA.
- Both Rehrs and P & G filed cross-motions for summary judgment.
- The district court (trial court) granted summary judgment in favor of P & G, concluding Rehrs was not a 'qualified individual' under the ADA because he could not perform the essential function of shift rotation.
- Rehrs (appellant) appealed the district court's grant of summary judgment to the U.S. Court of Appeals for the Eighth Circuit, where P & G is the appellee.
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Issue:
Is a uniformly applied shift-rotation schedule an essential function of a job under the Americans with Disabilities Act (ADA) when an employer presents legitimate business reasons for the policy, such as ensuring team equity and employee development?
Opinions:
Majority - Riley, Circuit Judge.
Yes. A uniformly applied shift-rotation schedule is an essential function of the job when supported by legitimate business reasons. P & G demonstrated that shift rotation was a core component of its 'High Performance Work System,' designed to promote equity, provide all employees with equal training and development opportunities, and foster a team concept. The court gave significant weight to the employer's judgment and found that exempting Rehrs would undermine the system and adversely affect other employees by forcing them to work less desirable shifts or miss development opportunities. The court reasoned that an employer's decision to provide a temporary accommodation does not concede that the function is non-essential. Furthermore, the ADA does not require an employer to eliminate an essential function, create a new position, or reallocate duties in a way that would cause other employees to work harder or be deprived of opportunities.
Analysis:
This decision reinforces the principle that courts will grant significant deference to an employer's judgment in defining the 'essential functions' of a job under the ADA. It establishes that a neutral, uniformly applied policy like shift rotation can be deemed essential if it is integral to the employer's business model and operational philosophy. The ruling makes it more difficult for an employee to obtain an accommodation that would require altering such a company-wide policy, especially when the employer can articulate negative impacts on other employees or its business structure. The case also clarifies that providing a temporary accommodation does not waive an employer's right to later assert that the accommodated function is, in fact, essential.
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