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Rehrs v. The Iams Company

United States Court of Appeals for the Eighth Circuit
486 F.3d 353 (8th Cir. 2007)


Facts

Beginning in 1997, Rehrs (plaintiff) worked for the Iams Company (defendant) as a warehouse technician. From 1997–1999, Rehrs worked a fixed daily shift from 4 p.m. until midnight. In 1999, Iams was acquired by Procter & Gamble (P&G), which instituted a new schedule of two 12-hour shifts for all warehouse technicians that rotated every two weeks, meaning Rehrs now worked alternating day and night shifts of 12 hours each. Rehrs, a Type I diabetic, worked this schedule from 2000 to early 2002, when he suffered a heart attack. Rehrs returned to work in August 2003, and in September 2003, Rehrs submitted a note from his doctor, requesting that P&G place him on a fixed, daytime schedule to help control his diabetes. P&G granted the request for 60 days, but then informed Rehrs the accommodation could not become permanent, because shift rotation was an essential job function. Rehrs sued P&G under the Americans with Disabilities Act (ADA), 42 U.S.C. § 12101 et seq., alleging unlawful disability discrimination. The district court granted summary judgment to P&G, based on its conclusion that even if Rehrs’s diabetes was a disability under the ADA, Rehrs was not protected by the statute, because he could not perform the rotating-shift schedule, which was an essential part of his job as a warehouse technician. Rehrs appealed.

Rule of Law

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Issue

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Holding and Reasoning (Riley, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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