United States Court of Appeals for the Eighth Circuit
486 F.3d 353 (8th Cir. 2007)
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
Holding and Reasoning (Riley, J.)
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