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Hoback v. City of Chattanooga
United States Court of Appeals for the Sixth Circuit
2013 WL 6698042 (2013)
In 2000, Michael Hoback (plaintiff) was hired by the City of Chattanooga (the city) (defendant) as a police officer. Hoback later enlisted in the United States Military and served in Iraq for over a year. Hoback returned to work in 2005 after being diagnosed by the Veterans Administration (VA) with post-traumatic stress disorder (PTSD). In 2009, a doctor at the VA attempted to have Hoback involuntarily committed after Hoback embellished the extent of his suicidal thoughts in an attempt to receive more benefits. Hoback spent one night at the hospital before being released. When the city learned of the attempted commitment, Hoback was placed on administrative leave and subjected to psychological testing. The city’s psychologist determined that Hoback could not safely perform his job due to his PTSD. The city told Hoback to take leave or apply for another job. Hoback obtained a second opinion, and the second doctor found that Hoback could return to his job, as long as he was monitored. Hoback was subsequently fired and later obtained a third evaluation. The third doctor found Hoback’s PTSD to be in remission and found Hoback to be fit for duty. The third doctor concluded that Hoback’s suicidal ideations were an attempt to receive more disability benefits. Hoback sued the city for violations of the Americans with Disability Act (ADA) and Rehabilitation Act. The district court denied the city’s motions for summary judgment and judgment as a matter of law. The case went to trial, and the jury awarded Hoback backpay, front pay, and damages for emotional distress. The city filed a motion requesting reduction in the amount of damages. The court granted a partial reduction for the backpay award. The city appealed all other orders to the Sixth Circuit Court of Appeals, arguing that Hoback’s receipt of disability benefits and false statements to increase the amount of Hoback’s benefits made Hoback incapable of performing his job.
Rule of Law
Holding and Reasoning (Smith Gibbons, J.)
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