Robert Wayne Goosen sued the Minnesota Department of Transportation (MNDOT) in the United States District Court for the District of Minnesota, raising claims of disability discrimination under the Americans with Disabilities Act (ADA). The district court granted summary judgment in favor of MNDOT, and Goosen appealed to the United States Court of Appeals for the Eighth Circuit.
Factual Overview:
In 2018, Goosen sustained an on-the-job injury while working as a heavy equipment field mechanic for MNDOT. The injury required multiple surgeries and physical therapy, causing Goosen to miss months of work. In 2021, after Goosen’s fourth surgery, his doctor determined he had reached maximum medical improvement but could return to work with certain physical restrictions. These restrictions included limitations on outstretching arms, reaching overhead, and climbing in and out of trucks and equipment.
MNDOT formed a Work Analysis Team to determine if they could reasonably accommodate Goosen’s restrictions. After multiple meetings and analysis, the team concluded that Goosen could not perform the essential functions of his job with or without reasonable accommodation. Goosen suggested he could be reassigned to a heavy equipment mechanic position, but MNDOT determined this was not a viable accommodation. When Goosen’s FMLA leave ended in October 2021, MNDOT considered him to have voluntarily resigned.
Goosen then filed this lawsuit, alleging MNDOT violated the ADA by failing to provide a reasonable accommodation. MNDOT moved for summary judgment, which the district court granted. Goosen appealed to the Eighth Circuit.
Legal Analysis:
Evidentiary Issue
The court first addressed Goosen’s challenge to the district court’s exclusion of three affidavits from MNDOT mechanics. The court affirmed the district court’s decision, finding no abuse of discretion in excluding the untimely disclosed affidavits.
ADA Failure to Accommodate Claim
The court then analyzed Goosen’s ADA claim, focusing on whether Goosen was a qualified individual under the ADA. This analysis centered on two main issues:
- Essential Functions of the Job
The court agreed with the district court that MNDOT’s Work Analysis Team accurately and reasonably defined the essential functions of a heavy equipment field mechanic. The court found that Goosen’s arguments against MNDOT’s definition of essential functions were not persuasive, noting that the employer’s judgment is highly probative in determining essential functions. - Reasonable Accommodation
The court determined that Goosen failed to make a facial showing that reassignment to a heavy equipment mechanic position was a reasonable accommodation. The court noted that Goosen did not provide sufficient evidence to show that the essential functions of this position were different from his previous role or that he could perform them with his restrictions. The court also highlighted MNDOT’s evidence suggesting that such a reassignment would not be reasonable.
The Eighth Circuit affirmed the district court’s grant of summary judgment to MNDOT on Goosen’s ADA failure to accommodate claim.
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