LaFata v. Dearborn Heights School District No. 7
United States District Court for the Eastern District of Michigan
2013 U.S. Dist. LEXIS 173731 (2013)
- Written by Noah Lewis, JD
Facts
In 2010, Adam LaFata (plaintiff) applied for the position of plant engineer with Dearborn Heights School District No. 7 (district) (defendant). The position required climbing ladders and lifting 55-plus pounds. LaFata worked for 10 years as a building supervisor at a community center and regularly used ladders, carried objects weighing 40-plus pounds, and was responsible for the complete maintenance of the inside and outside of the building. The district offered LaFata the job conditioned upon a physical examination. Dr. Joel Perlson conducted a cursory exam and concluded that LaFata suffered from a muscle-wasting disease and was not able to engage in two essential job functions: working above ground level and lifting more than 40 pounds. Before even reading the full report, the district revoked LaFata’s job offer despite the existence of reasonable accommodations, which were not discussed. LaFata filed suit alleging violations under the Americans with Disabilities Act (ADA) and Michigan’s Persons with Disabilities Civil Rights Act (PWDCRA). Both sides filed motions for summary judgment. The district argued that LaFata could not prove he was physically qualified to perform the job and that he posed a direct threat to himself and others. At oral argument, the district also argued that LaFata was not disabled because he worked in a similar job.
Rule of Law
Issue
Holding and Reasoning (Duggan, J.)
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