Byrne v. Avon Products

John Byrne (plaintiff) worked the night shift at Avon Products, Inc. (Avon) (defendant). After four years of exemplary service, Byrne began to exhibit strange behavior on the job. Night-shift employees sometimes used a carpenter’s shop as a break room, and security logs showed that Byrne had begun to frequent it. On the first night after Avon installed a camera to investigate, Byrne spent three hours of his shift reading and sleeping and was there with the lights off for six hours the following night. Byrne’s managers tried to discuss the problem on his next shift, but Byrne had already left after telling a coworker that he was not feeling well and would be out the rest of the week. Telephone calls were answered by Byrne’s sister, who told Avon that Byrne was very sick. When a colleague finally reached him, Byrne mumbled a few odd words and agreed to attend a meeting that he then did not attend. Approximately two weeks after Byrne’s unusual behavior began, Avon discharged Byrne for sleeping on the job and not reporting to the meeting. A psychiatrist concluded that Byrne was hallucinating by that point, and during the next few days, Byrne exhibited even more extreme symptoms of severe depression. After two months of treatment, Byrne was well enough to return to work, but Avon declined to reinstate him. Byrne filed suit under the Americans with Disabilities Act (ADA) and the Family and Medical Leave Act (FMLA). The district court found that neither statute authorizes misconduct on the job and entered summary judgment for Avon. Byrne appealed.