SW Legal studies in Business

Refusal to Provide Second Transfer to Paranoid Employee Not a Failure to Accommodate
Description Appeals court upheld the dismissal of a suit for failure to provide reasonable accommodation for a worker suffering from a mental disability, paranoia. The company had transferred him from one plant to another plant, to help him "escape" people who were persecuting him; the company's refusal to later send him back to the first plant at his request was not unreasonable.

Topic Employment Discrimination
Key Words Disability Discrimination; Mental Disability; Accommodation
C A S E   S U M M A R Y
Facts Tyler worked for Ispat Inland's Plant 2 from 1979 until the 1990s, when he began to complain that he was threatened by his coworkers. He asserted they threatened to burn down his house and poison him. These claims were not substantiated. A psychiatrist diagnosed him as suffering from "Atypical Depression R/O Delusional Disorder Persecutory." He prescribed antidepressant medication and, when Tyler returned to work, that he be reassigned to another location, Plant 7. Based on that request, Ispat transferred Tyler, at the same wages and benefits, to work at Plant 7. Tyler began to complain that workers there were persecuting him. He refused to take the medication he was prescribed. His psychiatrist diagnosed him as suffering from a "paranoid disorder," which Tyler disputes. Tyler demanded to be reassigned to Plant 2 to escape the workers he claimed were persecuting him at Plant 7. He also demanded a special parking place because he thought workers were tampering with his car. The company refused these requests; he sued for failure to accommodate his disability. The trial court dismissed the suit; Tyler appealed.
Decision Affirmed. Ispat made a reasonable accommodation when the company transferred Tyler from Plant 2 to Plant 7. No reasonable explanation was ever provided as to how his mental disability would be relieved by transferring him back to Plant 2, where the same workers he had previously complained about still worked. Tyler refused to allow the company to see his medical record. That failure to cooperate with his employer made it difficult for the company to justify his personal demands. Hence, there was not a denial of reasonable accommodation by not providing Tyler with another transfer or a special parking space.
Citation Tyler v. Ispat Inland Inc., 245 F.3d 969 (7th Cir., 2001)

Back to Employment Discrimination Listings

©1997-2002  SW Legal Studies in Business. All Rights Reserved.