Oswalt v. Sara Lee Corporation
Docket: 95-60402
Court: Court of Appeals for the Fifth Circuit; February 6, 1996; Federal Appellate Court
Original Court Document: View Document
Kevin Oswalt, an employee of Bryan Foods, Inc., filed a wrongful discharge lawsuit against Sara Lee Corporation, alleging violations of the Americans with Disabilities Act (ADA) and the Family and Medical Leave Act (FMLA). The United States District Court for the Northern District of Mississippi granted summary judgment in favor of the defendant, a decision Oswalt appealed. The Fifth Circuit Court of Appeals reviewed the district court's decision de novo. For a wrongful discharge claim under the ADA, Oswalt needed to demonstrate that he was a person with a "disability," defined as a physical or mental impairment that substantially limits one or more major life activities. Oswalt claimed his high blood pressure constituted a disability, but failed to provide evidence showing how it substantially limited his life activities. The court agreed with the district court's conclusion that high blood pressure alone did not qualify as a disability under the ADA, given the lack of evidence regarding its impact on major life activities. Regarding the FMLA claim, the Act entitles eligible employees to leave for a "serious health condition" that prevents them from performing their job. Oswalt cited both high blood pressure and food poisoning as serious health conditions. However, the food poisoning did not meet the statutory definition, while the high blood pressure was under treatment. Importantly, Oswalt's leave taken due to high blood pressure was in July 1993, prior to the FMLA's effective date of August 5, 1993. Thus, any leave before this date was not protected under the FMLA. The Fifth Circuit affirmed the district court's grant of summary judgment on both the ADA and FMLA claims, concluding that Oswalt did not provide sufficient evidence to support his allegations.