Morgan v. Allison Crane & Rigging LLC

Andrew Morgan (plaintiff) worked for Allison Crane & Rigging LLC (Crane) (defendant) as an industrial-machinery tradesman. In September 2020, Morgan injured his back while working. Morgan went to a chiropractor, complaining that it hurt to sit, walk, and turn from side to side. The chiropractor diagnosed Morgan with a bulged or herniated disc, recommended twice-weekly treatment, and advised Morgan to switch to light-duty work. In notes to Crane, the chiropractor stated that Morgan should be excused from bending and lifting from October 8 to November 25. Crane complied, placing Morgan on light duty. On November 13, a supervisor reprimanded Morgan for not wearing proper protective gear. On November 17, Morgan turned down an assignment because it conflicted with a chiropractor appointment. Later that day, Morgan rejected an alternate assignment because it involved sitting for an extended period. Morgan claimed that he instead worked in the work yard that day. However, Crane claimed that Morgan did not work that day, and on November 18, it terminated him for failure to follow the time-off-request procedure and other policies. Morgan sued Crane, alleging that Crane terminated him because of his injury and that doing so constituted disability discrimination violating the Americans with Disabilities Act (ADA). The district court concluded that Morgan’s back pain did not constitute a disability because it was minor and not permanent. The court therefore granted summary judgment in Crane’s favor. Morgan appealed.