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Eric Crawford v. Marvin T. Runyon, Postmaster General, United States Postal Service
Citation: 79 F.3d 743Docket: 95-1843EM
Court: Court of Appeals for the Eighth Circuit; June 10, 1996; Federal Appellate Court
Eric Crawford appealed the judgment of the District Court, which ruled in favor of Marvin T. Runyon, Postmaster General, following a bench trial regarding Crawford's discharge from the United States Postal Service. Crawford alleged discrimination under section 504 of the Rehabilitation Act of 1973, claiming he was fired based on fabricated threats against his acting supervisor, motivated by his mental health issues. The District Court had initially granted summary judgment to the Postal Service, but this was reversed on appeal, leading to a trial focused solely on whether Crawford made the alleged threats. The court determined that Crawford did not have a right to a jury trial because the defendant was sued in an official capacity as a representative of the United States, as clarified by relevant statutes and case law. During the bench trial, the court found that Crawford did indeed make threatening statements towards his supervisors, and thus, the reasons for his termination were not pretextual. The appellate court reviewed the District Court's factual findings and concluded they were not clearly erroneous, as testimony from multiple supervisors corroborated the claims against Crawford. Crawford's motion to supplement the record with impeachment evidence was denied, as the appellate court generally does not consider evidence not presented during the original trial. Consequently, the appellate court affirmed the District Court's decision.