David Pals v. Schepel Buick & Gmc Truck, Inc.

Citations: 220 F.3d 495; 10 Am. Disabilities Cas. (BNA) 1345; 2000 U.S. App. LEXIS 16180; 2000 WL 968673Docket: 99-3551

Court: Court of Appeals for the Seventh Circuit; July 14, 2000; Federal Appellate Court

Combined Opinion SummaryCombined Opinion Original

EnglishEspañolSimplified EnglishEspañol Fácil

David Pals, who suffered from muscular dystrophy, worked as the used car manager for Schepel Buick for 26 years. Despite his decreasing mobility, he successfully managed various tasks, including appraising trade-in cars and overseeing inventory. Following an accident in July 1996 that impaired his ability to walk, Schepel denied his return to work in February 1997, claiming his limitations prevented him from fulfilling the job's requirements. Pals sued under the Americans with Disabilities Act (ADA) and a jury awarded him $1,050,000 in damages.

Schepel argued that Pals was not a "qualified individual with a disability" under the ADA, asserting he could not perform all essential job functions. The court found that a rational jury could conclude that personal inspection of cars was not an essential function, especially since Pals had delegated this task for years prior to his accident. The court noted that accommodating Pals by relieving him of inspection duties remained viable after his accident.

Additionally, Schepel contended that there was no vacancy for Pals upon his return. However, the jury could determine that Wayne Wiarda, who filled in for Pals during his absence, was not permanently taking over the position. Pals's request to return part-time was also deemed reasonable under the ADA, as it is common for employees recovering from serious medical issues to transition back to full-time work gradually.

Lastly, Pals's applications for disability benefits did not preclude his ADA claim. Although he experienced significant disability in late 1996 and early 1997, he was engaged in physical therapy during this time. By February 1997, he had regained some mobility and was able to drive to the dealership, supported by testimony from his physical therapist that he could perform his job tasks.

Schepel argues that Pals' application for long-term disability benefits, in which he claimed he could not perform any tasks, presents an inconsistency that must be explained under the ADA. Pals contended he misread the form, thinking it inquired about tasks he could perform, a defense deemed weak by the court. However, this explanation was not so weak as to compel the jury to disbelieve him, allowing the jury's liability verdict to stand. 

In terms of damages, Pals sought approximately $350,000 for past losses, $1,700,000 for future losses, and an unspecified amount for mental distress, largely based on his own calculations. Schepel did not cross-examine or provide counter-evidence. The jury awarded Pals $1,050,000 in compensatory damages. Schepel requested a reduction to $100,000 under 42 U.S.C. § 1981a(b)(3)(B), citing the statute's cap for employers with between 100 and 201 employees. However, the court clarified that the cap applies only to nonpecuniary losses, while back pay is excluded from this limitation. Although front pay is not explicitly mentioned in the statute, it qualifies as equitable relief under the same statute, suggesting it is not subject to the damages cap.

Williams determined that section 706(g)(1) permits front pay as an equitable remedy, without addressing its implications for section 1981a. Section 1981a(b)(2) indicates that neither back pay nor front pay is counted against the cap on compensatory damages established in section 1981a(b)(3). Various circuit court decisions support this interpretation, while the 6th Circuit in Hudson v. Reno argued that excluding front pay from the cap rendered the term "future pecuniary losses" meaningless, although this view was later criticized in Pollard v. E.I. DuPont de Nemours Co. The courts noted that future medical expenses could also qualify as "future pecuniary losses." 

The text further highlights that the jury failed to distinguish compensatory damages under section 1981a from other monetary relief, creating uncertainty about the verdict's compliance with the $100,000 cap on compensatory damages. Schepel, the party appealing, did not adequately address this issue during trial, resulting in a forfeiture of benefits under section 1981a(b)(3). The appeal raised questions about whether a jury could determine amounts for back and front pay, given that section 1981a(c) allows for jury trials on compensatory and punitive damages without informing juries of the limitations in subsection (b)(3). There was an assumption that all issues were jury-triable, but the text suggests that issues, not actions, should be the basis for determining what is triable by jury or court.

Reinstatement and front pay are addressed as equitable remedies under sec. 706(g)(1), with judges holding discretion over their selection and amount, guided by jury findings. Although sec. 1981a(c) does not guarantee a jury trial for these remedies, parties can consent to a jury trial under Fed. R. Civ. P. 39(c), allowing juries to determine dollar amounts related to back pay and front pay, which are akin to lost wages in tort or contract cases. In this instance, neither party explicitly objected to the jury's involvement, and Schepel's request for a jury trial implies consent. The court affirmed the jury's authority to decide these issues, as Schepel did not present evidence to challenge Pals's financial loss estimates, leading to the upholding of the million-dollar award.