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Covelli v. National Fuel Gas Distribution Corp.

Citation: 49 F. App'x 356Docket: Docket No. 02-7015

Court: Court of Appeals for the Second Circuit; October 28, 2002; Federal Appellate Court

Narrative Opinion Summary

The judgment of the district court is affirmed in favor of National Fuel Gas Distribution Corporation regarding the claims brought by Richard Covelli under the Americans with Disabilities Act and the New York Human Rights Law. Covelli, an employee since 1987, suffered a work-related injury that led to his assignment to light duty positions. Despite medical reports indicating he could perform his prior role as a serviceman, the company did not reinstate him for two years, citing a reasonable belief that he was unable to perform the job based on information from Covelli himself. The court found that even if Covelli established a prima facie case of being perceived as disabled and subjected to adverse employment action, the company’s actions were justified. All arguments presented by Covelli were deemed meritless, resulting in the affirmation of the summary judgment granted to the company.

Legal Issues Addressed

Americans with Disabilities Act - Prima Facie Case

Application: The court considered whether Covelli established a prima facie case of discrimination under the ADA by being perceived as disabled and subjected to adverse employment action.

Reasoning: The court found that even if Covelli established a prima facie case of being perceived as disabled and subjected to adverse employment action, the company’s actions were justified.

Reasonable Accommodation under ADA

Application: The company's decision not to reinstate Covelli was based on a reasonable belief about his ability to perform job duties, which was considered justified under the ADA.

Reasoning: Despite medical reports indicating he could perform his prior role as a serviceman, the company did not reinstate him for two years, citing a reasonable belief that he was unable to perform the job based on information from Covelli himself.

Summary Judgment in Employment Discrimination Cases

Application: The court affirmed the summary judgment for the company, as Covelli's arguments were found to be without merit, supporting the company's rationale for its employment decisions.

Reasoning: All arguments presented by Covelli were deemed meritless, resulting in the affirmation of the summary judgment granted to the company.