EEOC v. Watkins Motor Line Inc.,
Introduction
The nexus between human resource management and the law lies in the fact that employers and employees must observe the law. In addition, the law steps in to protect the rights of the employees who invariably are the weaker parties in the employment relationship. In this paper, consideration is placed on the application of the Americans with Disabilities Act.
The case essentially turns on the interpretation of the anti-discrimination provisions under the Americans with Disabilities Act. It involves a worker, who previously served as a driver or dockworker. During his employment, he served under the job description that included activities such as climbing, kneeling, bending, and repeated heavy lifting, among others. On employment, the employee weighed around 345 pounds. He worked well without any incidents for over five years between 1990 and 1995. However, in late November, he would suffer a knee injury that would later occasion his leave of absence for a total of six months.
In brief, after his completion of the leave of absence, the employee attempted to return to work. His initial physician gave him a work release that was rejected by his employer for reasons that the physician had not considered the employer’s job responsibilities. The same physician would decline to make any follow up reports on the same. This prompted the employer to refer the employee to the industrial clinic physician. The latter after a thorough examination of the employee reached the position that the employee was not fit for the job responsibilities. In addition, it was established that the employee now weighed around 405 pounds. The conclusion of being unfit for the job responsibilities was tied to the safety standards. It was established that given the employee’s weight, his mobility was limited. The employee under the auspices of the EEOC filed a federal suit under the American with Disabilities Act based on the fact that the former’s employment termination was discriminative of his status as an obese person. However, both the District Court and the Sixth Circuit Court disagreed with EEOC’s argument. The two courts concurred in their holding that morbid obesity was not envisaged under the Act and therefore such obesity could not enjoy the protection of the law.
The District Court ruled in favor of the employer. The Court was of the view that the precise provisions of the Americans with Disabilities Act, in as far as obesity cases were concerned, was limited to obesity consequent of psychological conditions. In the court’s opinion, for an employee to find protection under the Act, he had to prove that the obesity was consequent of psychological conditions. The Court found that the silence of the Act on morbid obesity necessarily meant that Act does not cover the same. This conclusion meant the employee could not rely on the Act in seeking to bar the termination of his employment.
On appeal to the Sixth Circuit Court, the EEOC lost for the second time. The Sixth Circuit Court affirmed the ruling of the District Court. The former court equally concurred with the limited interpretation of the provisions of ADA arguing that the employee seeking reliance on the same bore the burden of proving that obesity was consequent of psychological conditions. It was the court’s learned position that the anti-discrimination law was specific and could not be applied generally on any cases. This limited interpretation afforded the employer an opportunity to dismiss the employee on grounds of the unfit state of the latter.
Meaning for Watkins Motor Line Inc., and for Business generally
The case essentially reflects some of the protection afforded to employers. The court necessarily allowed Watkins Motor Line Inc., to dispense with the employee who was in fact unfit for the job description. In that context, it can be argued that the meaning the case afforded to the organization was the ability to exercise freedom of contract in a free market. This is to the extent that the law only gives a guiding framework of operation. The two contracting parties leave the details in terms of job descriptions and job requirements for determination. This is a perfect example of free markets where the buyers and sellers are allowed to reach their own bargain.
In business, the case laid down the framework for the application of ADA. In essence, the message from the courts was that ADA could not be applied to open the floodgates for legal suits. The business community keen to retain their freedom of contract, even as the law steps in to provide mandatory requirements, must have appreciated the restrictive interpretation. For the employees the case obviously reminded them of just how limited ADA and other laws could be in as far as securing their rights is concerned. The fact that morbid obesity could not extend protection meant that the laws available provided no relief in cases. This must have been unfortunate given the fact that in many cases, obesity may be unexplainable and, therefore, employees need such protection.
Legal precedent set
In terms of precedent, the court made it clear that the Americans with Disabilities Act could only be extended to cover obesity cases that are associated with psychological conditions. In other cases, the Act would be given a limited interpretation to exclude protection. The exclusionary approach gives a precedent in favor of employers as opposed to a liberal approach which would extend cover to other categories of obese persons.
Role of Federal Enforcement Agency
The case squarely fell within the purview of the Equal Employment Opportunities Commission otherwise referred to as EEOC. EEOC was created pursuant to Title VII to, among others, secure the protection of employees. In that breadth, EEOC is charged with pursuing cases considered discriminative on employees. In this case, EEOC took the complaint filed by the complainant employee. It was then the responsibility of EEOC to ensure the enforcement of the employee’s right. The same was pursued through the filing of suit at the District Court. In this particular case, EEOC even appealed against the decision of the District Court at the Sixth Circuit Court. In terms of the role of EEOC in such cases, one can bring out two factors. One, the EEOC ought to advise the employee. An employee may fail to make the right interpretation of the law. In such cases, the onus lies with EEOC to consider the facts and the law. In doing so, the EEOC must come up with legal advice. The second limb entails the way forward. In such cases, the EEOC either takes up the matter for further pursuit or rejects the complaint filed with them. For the cases they opt to pursue further, they may negotiate with the defendant employer involved or file suit in the court. The second option is preferable not because of its litigious character, but because of the fact that it allows room for court interpretation which is lays good precedent.
Conclusion
The paper has considered the application of the Americans with Disabilities Act. It has brought out its exclusionary approach that necessarily omits morbid obesity from protection of the law.
References
Equal Employment Opportunitie Commission v Watkins Motor Line Inc.,, 05-3218 (United States Court of Appeal September 12, 2006).
Cavico, F., & Mujtaba, B. (2012). Discrimination and the aging American workforce: legal analysis and management strategies. Journal of Legal Issues and Cases in Business, 1-40.
Mello, M., & Rosenthal, M. (2008). Wellness Programs and Lifestyle Discrimination —the Legal Limits. The New England Journal of Medicine, 192-199.
