Eshleman v Patrick Industries, Inc.
United States Court of Appeals for the Third Circuit
961 F.3d 242 (2020)
Facts
William Eshleman (plaintiff) was a truck driver for Patrick Industries, Inc. (company) (defendant). Eshleman took two months of medical leave for lung biopsy surgery. Six weeks after returning to work in full capacity, Eshleman suffered a severe respiratory infection. In total, Eshleman missed just under 10 weeks of work in a 15-week period due to both medical issues. One day after Eshleman’s physician approved a return to work, the company fired Eshleman, citing performance issues. However, Eshleman’s formal performance reviews were excellent. The company then changed the reason for termination to Eshleman’s failure to call out sick during his infection period and then again to behavioral issues. Eshleman filed suit against the company, arguing that the company regarded him as disabled due to his respiratory troubles and fired him due to that perception in violation of the Americans with Disabilities Act (ADA). The district court granted the company’s 12(b)(6) motion to dismiss the case. The court found that Eshleman’s impairments were not covered under the ADA because they lasted or were expected to last less than six months and were considered transitory and minor. Eshleman appealed to the Third Circuit.
Rule of Law
Issue
Holding and Reasoning (McKee, J.)
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