AutoZone Inc. just had a case remanded back to district court in favor of an employee who claimed the company failed to accommodate his severe back pain and related physical limitations. The real stickler of the case – involving a former salesman in the chain’s Macomb, Ill., store – is the appeal court’s ruling that Memphis, Tenn.-based AutoZone should have accepted his personal testimony that he was “substantially limited in the major life activity of caring for himself,” even without any medical documentation to back that particular claim up.
As this account on the hr.blr.com site lays it out, the salesman was so debilitated by his back pain that certain kinds of activities — including just mopping the floor — could lead to swelling, spasms and sometimes even vomiting. The story’s a bit complicated, with two different medical leaves and requested medical restrictions involved, the worker’s threatened firing and then ultimate firing, and appellate judges’ rejections of many facets of the salesman’s claims – including the fact that the ADA Amendments Act that became effective in 2009 did not apply to his claims of 2003 through 2005. In fact, to understand the case fully, it’s probably best to read the appellate judges’ entire ruling.
Bottom line, though, the case is heading back to court because appeals court judges ruled AutoZone should have accepted the salesman’s testimony that he was “substantially limited” and should have accommodated him, even though no medical documentation was submitted about his specific limitations. (Both the employee and his wife testified that she had to help him dress and bathe four or five days a week.)
As the hr.blr site points out, “employees need not submit medical documentation of substantial limitations; employers must accept what the employees themselves say about their limits.”