Quiles-Quiles v. Henderson

Genaro Quiles-Quiles (Quiles) (plaintiff) worked for the United States Postal Service. Quiles was supervised by Doris Vazquez. Soon after Quiles started his position, Vazquez began routinely interfering with Quiles’s job duties and yelling at him in front of other employees and customers, causing Quiles to suffer a panic attack and miss work for medical necessity. Quiles complained to Vazquez’s supervisor, Virgilio Lopez, who did nothing. After returning to work, Vazquez increased her interference with Quiles’s work, and her supervisor continued to ignore Quiles’s complaints. Vazquez drove her truck at Quiles while he was crossing the street outside the post office, causing Quiles’s anxiety to increase and prompting another complaint to Lopez, as well as a police report. Quiles’s psychiatrist prescribed a leave of absence and recommended a reassignment away from his cashier duties after returning to work. Quiles brought the medical documentation to Lopez in a sealed envelope, which Lopez proceeded to open and share with Vazquez. Vazquez called Quiles crazy, and she and Lopez laughed at Quiles. All the supervisors continued to name-call Quiles at work and joke about Quiles’s use of medication and need for a psychiatrist. Quiles filed a complaint with the Equal Employment Opportunity Commission (EEOC), claiming that the supervisors harassed him based on his mental disability. The harassment continued with more jokes, additional yelling, and threats of psychical conflict. Quiles’s psychiatrist declared Quiles totally disabled due to severe depression, and due to continued harassment, Quiles had to take multiple leaves of absence and was hospitalized twice. Quiles filed suit under the Rehabilitation Act against the postmaster general (defendant), alleging that his supervisors harassed him for his disability and retaliated against him for complaining. The district court granted the postmaster general’s motion for judgment as a matter of law, finding, among other things, that Quiles did not prove that he suffered a hostile working environment or retaliation. Quiles appealed to the First Circuit.