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Equal Employment Opportunity Commission v. Heartway Corp.

466 F.3d 1156 (2006)

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Equal Employment Opportunity Commission v. Heartway Corp.

United States Court of Appeals for the Tenth Circuit

466 F.3d 1156 (2006)

Facts

Janet Edwards (plaintiff) was diagnosed with hepatitis C, a viral disease transmitted through blood-to-blood contact, but when she applied to work as a dietary aide at a nursing home operated by Heartway Corporation (Heartway) (defendant), her blood had no detectable amount of hepatitis C. Although a doctor monitored Edwards’s hepatitis C, Edwards indicated on her application that she was not currently under a doctor’s care or taking medications. Edwards was a cook at the nursing home for nearly a year. One day, Edwards cut her hand at work, and Edwards informed the director of nursing of the cut and her hepatitis diagnosis. The director of nursing informed Edwards that she could not return to work without a doctor’s permission. Edwards promptly obtained a doctor’s letter clearing her return to work, but Edwards was terminated before she could deliver it. Edwards showed facility administrator Mitchell Townsend the doctor’s letter and asked him to reinstate her. Townsend refused, allegedly telling Edwards that she could not work in the kitchen because she had hepatitis C and that he fired Edwards because she lied on her application. Edwards filed a complaint with the Equal Employment Opportunity Commission (EEOC) (plaintiff). During the EEOC investigation, Townsend asked an EEOC investigator, “How would you like to eat food containing her blood, if she ever cut her finger?” and complained that clients would leave the nursing home if they learned of Edwards’s diagnosis. The EEOC sued Heartway, claiming that Heartway violated the Americans with Disabilities Act (ADA) by firing Edwards because Heartway perceived her hepatitis C diagnosis as a disability. The jury found that Heartway discriminated against Edwards due to perceived disability and awarded her $20,000 in compensatory damages plus backpay. Both parties appealed: the EEOC challenged the district court’s refusal to allow the jury to consider punitive damages, and Heartway contested the jury’s verdict.

Rule of Law

Issue

Holding and Reasoning (Ebel, J.)

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