Barrett v. Union Pacific Railroad
- Vince Chhabria
- 3:19-cv-06377
- U.S. District Court · Northern District of California
- 2
In Barrett v. Union Pacific Railroad, Judge Chhabria denied summary judgment on ADA claims but granted it on punitive damages.
Robin F. Barrett’s disability discrimination and failure-to-accommodate claims proceed to trial, while her punitive-damages claim cannot go to the jury; Union Pacific partially prevailed on its motion.
What happened
In Barrett v. Union Pacific Railroad, Robin F. Barrett brought disability discrimination and failure-to-accommodate claims against Union Pacific under the Americans with Disabilities Act. Union Pacific asked the court to decide those claims without a trial.
The court found a factual dispute about whether lifting more than ten pounds was an essential part of Barrett’s job as a gang bus driver. It also found that a jury could decide that Barrett was disabled because of her heart condition, suffered an adverse employment action when she was placed on unpaid leave, and was denied a reasonable accommodation.
The court denied Union Pacific’s motion for summary judgment on the disability discrimination and failure-to-accommodate claims, allowing those claims to proceed to trial, but granted the motion on Barrett’s punitive-damages claim. Judge Chhabria ruled that Barrett had not identified evidence showing malice or reckless indifference.
The detailed version
- Barrett v. Union Pacific Railroad · No. 3:19-cv-06377
- Vince Chhabria
- Jan. 25, 2021
Background
Robin F. Barrett asserted disability discrimination and failure-to-accommodate claims under the Americans with Disabilities Act, or ADA. She also sought punitive damages. Union Pacific Railroad moved for summary judgment, asking the court to resolve the claims without a trial.
Disability Claims
The court denied summary judgment on Barrett’s disability discrimination and failure-to-accommodate claims. A central issue was whether Barrett was a “qualified person” under the ADA. That question depended on whether tasks requiring a gang bus driver to lift more than ten pounds were essential functions of the job.
The court found a genuine factual dispute requiring a jury’s decision. Barrett and Becker testified that the lifting tasks occurred relatively infrequently and that a gang could complete its work relatively easily without assistance from the driver. That testimony conflicted with Union Pacific’s job description.
The court also concluded that the law and evidence would not prevent a reasonable jury from finding that Barrett was disabled because her heart condition prevented her from lifting more than ten pounds, that Union Pacific took an adverse employment action by placing her on unpaid leave rather than allowing her to continue working for pay, and that Union Pacific denied her a reasonable accommodation. The court found that Farrar’s conclusory statement that Union Pacific could not provide alternative employment or accommodations for an employee with a lifting restriction was insufficient to support summary judgment. The disability claims therefore must proceed to trial.
Punitive Damages and Disposition
The court granted summary judgment on Barrett’s punitive-damages claim. It found that Barrett had not identified evidence from which a jury could conclude that Union Pacific acted with malice or reckless indifference when it placed her on medical leave. Accordingly, that claim could not go to the jury.
Judge Vince Chhabria ordered that Union Pacific’s motion for summary judgment was granted in part and denied in part.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.