Employee Was Not Disabled And His False Injury Report Could Not Support Claim Of Workers' Compensation Retaliation
In this case, a terminated employee sued his former employer, asserting a claim for discrimination under the Americans with Disabilities Act (ADA), and an Iowa common law claim for discharge in retaliation for exercising his workers' compensation rights.
The
District Court granted summary judgment for the employer. On appeal, the 8th
Circuit affirmed, holding that: (1) the employee was not substantially limited
in the major life activity of working, so as to be disabled under the ADA, where
work restrictions imposed upon him due to a back injury were temporary and did
not prevent him from continuing to work or from finding comparable employment
with another employer after his termination; and (2)
any protected
activity by the employee, in the form of reporting that he had been injured, was
not the cause of his termination, and his employer thus was not liable for
workers' compensation retaliation under Iowa law. The employer's decision-maker
thoroughly investigated the alleged injury, uncovered numerous grounds for
disbelieving the injury report, and terminated him for submitting a false
report. Terminating an employee for falsely reporting an injury did not
constitute retaliation for the exercise of workers' compensation rights
protected by Iowa public policy.
Napreljac v. John Q. Hammons Hotels, Inc.
The 8th Circuit Court of Appeals’ jurisdiction includes North Dakota, South Dakota, Minnesota, Nebraska, Iowa, Missouri and Arkansas.