Phelps v. Field Real Estate Co.
United States Court of Appeals for the Tenth Circuit
991 F.2d 645 (1993)
John Phelps (plaintiff) was hired as a manager of a commercial real-estate division for Field Real Estate Company (Field) in February 1985. Phelps reported to W. Douglas Poole, the chairman of the board and the chief executive officer of Field. Phelps generally received positive performance reviews over the next few years, but consistently failed to meet Poole’s sales expectations. In 1986, Phelps was diagnosed with the virus that causes acquired immunodeficiency syndrome (AIDS). In March 1988, Phelps’s condition was anonymously disclosed to Poole. Although initially concerned, Poole was satisfied after receiving a doctor’s note that Phelps’s condition would not interfere with Phelps’s ability to work. In the summer of 1988, the real-estate commercial division had particularly poor sales. Poole decided to reorganize Field and placed an advertisement for a real-estate commercial-division manager in an apparent effort to prompt Phelps to resign. In August 1989, over 14 months after Phelps disclosed that he had the AIDS virus, Field discharged Phelps, in part due to poor performance and in part because of the reorganization. Phelps sued Field, claiming that the discharge violated the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. § 1140, because the discharge interfered with Phelps’s receipt of benefits under ERISA. The district court ruled that Phelps had failed to establish that Field had the requisite intent under ERISA and ruled in favor of Field. Phelps appealed.
Rule of Law
Holding and Reasoning (Brown, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 725,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.Learn about our approachRead more about Quimbee
Here's why 725,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 45,600 briefs, keyed to 983 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.