Case Law - Legal Summary
A Project of the Southeast ADA Center and the Burton Blatt Institute (BBI) - Syracuse University

Summary of EEOC vs. Federal Express Corp.

Key Issues:  Reasonable Accommodation; Retaliation; Punitive Damages

Ronald Lockhart is deaf and is unable to speak or read lips.  Instead he is fluent in American Sign Language ("ASL"), which is his primary language and English is his second.  He was employed by FedEx as a package handler at FedEx’s Baltimore-Washington International Airport facility.  Lockhart did not need or request accommodations for his daily job activities of handling packages such as sorting; however, he did need and request accommodations for the mandatory employee meetings, which addressed job training, safety and benefits.  Lockhart testified that his need for accommodations became imperative after September 11, 2001, although his requests for an interpreter were denied.  Lockhart was excluded from several meetings that trained and informed FedEx employees on security concerns such as anthrax exposure.

After nearly three years of repeatedly being denied an ASL interpreter and other accommodations for employee meetings and training sessions, Lockhart filed a formal complaint with the EEOC claiming that FedEx violated the ADA.  The same month that Lockhart’s supervisor learned of his discrimination complaint to the EEOC, FedEx gave him an official form for requesting disability accommodations.  However, FedEx fired Lockhart a few weeks later claiming he had poor attendance.  The EEOC tried to reconcile the situation through negotiations, but did not succeed.  As a result, the EEOC filed suit complaining that FedEx violated Title I of the ADA by failing to provide reasonable accommodations and for discharging him in retaliation for his discrimination complaint. 

The District Court of Maryland awarded Lockhart the sums of $8,000 in compensatory damages and $100,000 in punitive damages, based on a jury finding against FedEx for failing to reasonably accommodate Lockhart under the ADA.  FedEx appealed to the Fourth Circuit, questioning whether (1) there was enough evidence to submit the question of punitive damages to the jury and (2) the $100,000 punitive damages award was constitutionally excessive.

The EEOC proved that (1) FedEx was aware of Lockhart’s disability, (2) FedEx was aware of their legal obligation to provide reasonable accommodations under the ADA and recklessly disregarded their obligations, and (3) $100,000 in punitive damages was not constitutionally excessive. The Appellate Court affirmed the district court’s award to Lockhart of $8,000 in compensatory and $100,000 in punitive damages.

Federal Express filed a Petition for Writ of Certiorari with the United States Supreme Court on April 22, 2008 to determine whether the Fourth Circuit used an improper standard in allowing an award of punitive damages.  On October 6, 2008, the Supreme Court denied the petition for review by Federal Express Corporation.  Therefore, the punitive damages award of $100,000, upheld by the Fourth Circuit’s unanimous decision, prevails.

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