EEOC v. Autozone, Inc.

In ADA action alleging that defendant-employer failed to accommodate plaintiff during March to September 2003 time frame with respect to his mopping duties at time when defendant was experiencing back pain, jury could properly find in favor of plaintiff even though prior jury trial found that plaintiff had been unable to perform his job for period beginning in January of 2004. While defendant argued that plaintiff’s back condition was constant throughout both periods of time, record showed that plaintiff experienced flare-up in September of 2003 that forced him to take lengthy leave of absence and otherwise explained difference in plaintiff’s ability to perform his job. Moreover, jury could properly award plaintiff $100,000 in compensatory damages and $200,000 in punitive damages where: (1) compensatory damage award was supported by evidence that plaintiff experienced physical pain during relevant time period that played role in his inability to perform other daily activities; and (2) punitive damages award was supported by evidence that defendant’s official, who was aware of plaintiff’s disability, did not address plaintiff’s disability through defendant’s typical procedures, and that certain efforts were made to cover up defendant’s prior failure to accommodate plaintiff’s disability. Remand, though, was required where Dist. Ct. entered “obey-the-law” injunction without placing any reasonable time limitation.