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Carlton v. Henderson

Citation: 64 F. App'x 512Docket: No. 02-1129

Court: Court of Appeals for the Sixth Circuit; May 12, 2003; Federal Appellate Court

Narrative Opinion Summary

This case involves a discrimination lawsuit under the Rehabilitation Act, where the appellant, Carlton, alleged that the Postmaster General discriminated against her due to a perceived disability. Following a job offer, Carlton underwent a physical screening that raised health concerns, leading to a request for further medical documentation and a physical examination. Carlton provided the documentation but failed to attend the physical exam, resulting in the rescission of her job offer. The district court, after a jury trial, found that although Carlton was perceived as disabled, there was no intentional discrimination by the Postal Service. The court denied Carlton's motions for judgment notwithstanding the verdict and for a new trial, which Carlton appealed. The appellate court affirmed the district court's judgment, concluding that the jury's verdict was reasonable and supported by evidence that her non-hire was due to her failure to attend the physical exam. The court also upheld the procedural policy of removing candidates who miss required physicals, deeming it a legitimate practice. Consequently, Carlton's appeal was denied, maintaining the jury's original decision.

Legal Issues Addressed

Failure to Attend Physical Examination

Application: The court found that Carlton's failure to attend the required physical examination was a valid reason for rescinding her job offer.

Reasoning: Based on this evidence, a reasonable jury could conclude that Carlton was not hired due to her failure to appear for the physical, not due to perceived disability.

Judgment as a Matter of Law

Application: Carlton's motion for judgment as a matter of law was denied, as the jury's decision was supported by substantial evidence.

Reasoning: Consequently, Carlton's motions for judgment as a matter of law and for a new trial were rejected, affirming the district court's judgment.

Jury Verdict and Interpretation

Application: The court held that the jury's verdict was reasonable and based on evidence, despite Carlton's claims to the contrary.

Reasoning: The court affirmed the district court's judgment, finding that Carlton's conclusion was one of several reasonable interpretations a jury could reach.

Procedural Requirements for Employment

Application: The Post Office's policy of removing candidates who do not attend required physicals was upheld as a legitimate employment practice.

Reasoning: Undisputed testimony from Carolyn Robinson, a postal personnel specialist, indicated that the Post Office removes candidates from the hiring register who fail to attend a physical appointment.

Rehabilitation Act and Discrimination

Application: The court evaluated whether Carlton's perceived disability constituted intentional discrimination under the Rehabilitation Act.

Reasoning: The jury found that while Carlton was perceived as disabled, the Postal Service did not intentionally discriminate against her.