7th Circuit Affirms Jury Verdict for Employer in ADA Disabilty Discrimination Lawsuit

On December 4, 2019, the 7th Circuit held that a jury verdict in favor of a defendant-employer in a disability discrimination lawsuit under the Americans with Disabilities Act ("ADA") was not against the manifest weight of the evidence.  Stegall v. Saul, Commissioner of Social Security, No. 18-2345 (7th Cir. Dec. 4, 2019).  The plaintiff claimed that after she interviewed for a position, she received an offer of employment from the defendant at the end of her interview.  She also claimed that when and because she subsequently disclosed her physical and mental disabilities, the defendant rescinded the offer of employment in violation of the ADA.  She filed claims of disability and race discrimination in federal court.  After a trial, the jury found that the plaintiff had a disability, that the defendant regarded her as having a disability, and that the defendant failed to hire the plaintiff.  However, the jury also found that even without her physical disability, the plaintiff would not have been hired; and that her non-hiring was not unlawfully motivated based on her disabilities.

The plaintiff appealed, claiming that the jury verdict was against the manifest weight of the evidence, and that the district court improperly admitted irrelevant and prejudicial evidence that the defendant hired another applicant with a disability for the position instead of her.  The plaintiff argued that the fact that she lost out to another person with a disability is irrelevant.  However, her claim of irrelevancy would only work if she lost out because of her disability and for no other probable reason.  Although the hired applicant's disability status was not conclusive or outcome determinative, it was relevant and admissible as evidence tending to rebut the plaintiff's claim of discriminatory intent based on disability.  The record contained ample evidence to support the jury's verdict that the defendant's hiring decision was not motivated by intentional discrimination.  The hired applicant was objectively more qualified for the position.  The plaintiff's claim of discrimination failed to support a different jury verdict, even without the introduction of the relevant and non-prejudicial evidence regarding the successful job applicant.  The interviewer testified that she was highly motivated by the defendant's work for disabled Americans.  She also testified about her son's disability and the profound impact it had on her family.  Thus, the 7th Circuit found that the district court did not commit any reversible error and affirmed the verdict and judgment in favor of the defendant.