Lansdale v. UPS Supply Chain Solutions, Inc.

Background

Michael L. Lansdale worked as a Region Sales Manager for UPS Supply Chain Solutions and traveled nearly every week. UPS required him to use a corporate credit card for travel expenses and prohibited personal purchases. After an internal audit found inconsistencies between his card use and expense reports, UPS investigated.

During an interview, UPS investigators asked Lansdale about his drinking. Lansdale wrote and signed a statement acknowledging that he sometimes used his corporate card to hide alcohol-related charges from his wife. UPS terminated him the next day. Lansdale sued, alleging that UPS violated the Americans with Disabilities Act (ADA) and the Minnesota Human Rights Act (MHRA) by discriminating against him because of alcoholism or because UPS regarded him as disabled. He also claimed that UPS made prohibited disability-related inquiries during the interview.

A jury found for UPS on all counts. Lansdale then filed a renewed motion for judgment as a matter of law, a motion for a new trial, and an alternative motion to alter or amend the judgment.

Judgment as a Matter of Law

The court denied the renewed motion for judgment as a matter of law on the disability-related-inquiries claim. Even assuming the interview questions were disability-related inquiries, the jury could reasonably find that they did not cause Lansdale’s termination. The jury could instead rely on Lansdale’s written admission about personal card charges and evidence that UPS decisionmakers believed he had violated company policy. The decisionmakers also testified that the termination decision was not based on the interview and had been made before it occurred.

The court also denied judgment as a matter of law on the ADA and MHRA discrimination claims. The jury could reasonably find that Lansdale had not proved that he had alcoholism, that his alleged alcoholism substantially limited a major life activity, or that it was a motivating factor in his termination. The jury could also reasonably find that UPS did not regard Lansdale as disabled or rely on such a belief when terminating him.

Motion for a New Trial

The court denied a new trial based on the weight of the evidence. It found that the verdict was not so contrary to the evidence that it constituted a miscarriage of justice.

The court rejected Lansdale’s arguments concerning testimony from four witnesses. It had previously found that UPS did not violate discovery rules because the witnesses were identified in a supplemental disclosure before discovery ended. The court alternatively found that Lansdale had sufficient notice of the witnesses’ relevance and could not show reasonable surprise or prejudice. It also found that the challenged testimony did not substantially influence the verdict because other evidence independently supported UPS’s position.

The court denied a new trial based on evidence Lansdale said UPS had not produced because he did not identify the specific evidence, explain the claimed prejudice, or show an effect on the trial. The court also upheld its decision to bar arguments that UPS had a duty to provide a reasonable accommodation. Lansdale had not clearly requested an accommodation, had not shown that he told UPS his alleged disability required one, and had not shown that UPS believed an accommodation was needed.

The court further rejected Lansdale’s challenges to the jury instructions. It held that limiting the disability-inquiry claim’s injury to termination was appropriate because termination was the only tangible injury supported by the trial evidence. The court also declined to give a spoliation instruction concerning UPS’s missing personnel file because Lansdale offered no evidence that UPS intentionally destroyed the file in bad faith or that he was prejudiced by its absence. The remaining instruction challenges did not establish legal error.

Motion to Alter or Amend the Judgment

The court denied Lansdale’s alternative motion to alter, amend, or correct the judgment. It found no manifest error of law or fact and no newly discovered evidence supporting that relief.

Disposition

The court denied Lansdale’s motion for judgment as a matter of law, motion for a new trial, and alternative motion to alter, amend, or correct the judgment. It directed that judgment be entered accordingly, leaving the jury’s verdict for UPS in place.