Gilbert Wraith v. Wayfair Inc

CourtCourt of Appeals for the Third Circuit
DecidedSeptember 11, 2024
Docket23-2400
StatusUnpublished

This text of Gilbert Wraith v. Wayfair Inc (Gilbert Wraith v. Wayfair Inc) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gilbert Wraith v. Wayfair Inc, (3d Cir. 2024).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ____________

No. 23-2400 ___________

GILBERT WRAITH, Appellant

v.

WAYFAIR, INC.; WAYFAIR, LLC

____________

On Appeal from the United States District Court for the District of New Jersey (D.C. No. 3-20-cv-06054) District Judge: Honorable Zahid N. Quraishi ____________

Submitted Under Third Circuit L.A.R. 34.1(a) (September 6, 2024)

Before: JORDAN, HARDIMAN, and PORTER, Circuit Judges.

(Filed: September 11, 2024)

OPINION* ____________

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. HARDIMAN, Circuit Judge.

Gilbert Wraith appeals a summary judgment entered in favor of his former

employer, Wayfair. We will affirm.

I

Wayfair is a national furniture retailer. In October 2019, Wraith began working as

a Warehouse Associate for Wayfair in Cranbury, New Jersey. He was paid $15.50 per

hour to “[u]nload and receive inbound furniture orders,” which “require[d] manually

moving large, heavy goods.” App. 273. As a Warehouse Associate, Wraith had to “be

comfortable repeatedly lifting up to 75 pounds unassisted and maneuvering product 150+

pounds unassisted or via team lift.” Id. Indeed, in the one-page explanation of the job,

this requirement—the ability to lift up to 75 pounds unassisted—appears twice: at the top

of the bullet-point lists of “What You’ll Do” and “What You’ll Need” as a Warehouse

Associate. Id. (boldface removed).

Unfortunately, Wraith was injured on the job on February 3, 2020. As Wraith

testified, his right shoulder “just stopped working,” which “was extremely painful.” App.

137. Afterward, he “couldn’t lift [his] shoulder and it was extremely painful all the time.”

Id. Paperwork from doctor’s appointments on February 4, February 7, and February 14

noted only that Wraith could “not return to work.” App. 301, 308, 320. For each

2 appointment, the doctor left blank the part of the form used to note potential

accommodations and likewise did not suggest any possible return date. Id.1

Wayfair terminated Wraith’s employment on February 18, after he had used up all

his leave time. At the same time, the company told Wraith he was eligible for re-hire if he

re-applied after recovering. On May 4, Wraith’s doctor cleared him to return to work, but

Wraith chose not to re-apply to Wayfair.

Wraith sued Wayfair in New Jersey state court, alleging violations of three state

laws: (1) the Law Against Discrimination; (2) the Worker’s Compensation Act; and

(3) the Paid Sick Leave Law. Wayfair removed the case to federal court based on

diversity of citizenship and filed a motion for summary judgment. The District Court

granted the motion, and Wraith timely appealed.2

II

We review the District Court’s summary judgment de novo. See Freedom From

Religion Found., Inc. v. Cnty. of Lehigh, 933 F.3d 275, 279 (3d Cir. 2019). The District

Court granted summary judgment after finding “no genuine dispute as to any material

fact” and because Wayfair was “entitled to judgment as a matter of law.” Fed. R. Civ. P.

56(a).

A

1 A doctor’s note from March 19 similarly stated that Wraith was “[u]nable to do any work” due to a “total temporary disability.” App. 333. It estimated that Wraith could return to full duty only “[a]fter [his] next follow up,” on an unspecified date. Id. 2 The District Court had jurisdiction under 28 U.S.C. § 1332. We have jurisdiction under 28 U.S.C. § 1291. 3 We begin with Wraith’s claim under New Jersey’s Law Against Discrimination.

N.J. Stat. Ann. § 10:5-1 et seq. That law makes it “an unlawful employment practice to

deny to an otherwise qualified person with a disability the opportunity to . . . maintain

employment . . . solely because such person is a person with a disability,” N.J. Stat. Ann.

§ 10:5-29.1, “unless the nature and extent of the disability reasonably precludes the

performance of the particular employment,” N.J. Stat. Ann. § 10:5-4.1. Thus, to establish

a prima facie case of discriminatory discharge or failure to accommodate, Wraith had to

demonstrate that he was qualified to perform the essential functions of the job, with or

without reasonable accommodations. See Victor v. State, 4 A.3d 126, 141–42 (N.J. 2010)

(discriminatory discharge); Richter v. Oakland Bd. of Educ., 252 A.3d 161, 172–73 (N.J.

2021) (failure to accommodate).

We agree with the District Court that Wraith could not perform the essential

functions of a Warehouse Associate after his injury. In determining what counts as an

essential job function, New Jersey law places great weight on the written job description.

See Raspa v. Off. of Sheriff, 924 A.2d 435, 443–44 (N.J. 2007). Here, Wraith understood

the duties of a Warehouse Associate at the start of his employment. The written job

description stipulated that the position required “repeatedly lifting up to 75 pounds

unassisted”—and maneuvering over 150 pounds “unassisted or via team lift.” App. 273.

Yet Wraith testified that, in the week after the injury, he was able to lift only

“[m]inimal weight”—such as a “[c]ell phone”—with his right shoulder. App. 402–03.

None of the medical records from the weeks after his injury indicated when Wraith might

be able to return to work. And although the medical forms provided check boxes to

4 indicate any “restrictions” (such as “[l]eft handed duty only”) that might allow for a

“[r]eturn to work,” these were all left blank. App. 301, 308, 320. Wraith “was not

qualified to complete the required tasks included in his job description, even with . . .

accommodation.” Wraith v. Wayfair, Inc., 2023 WL 4488045, at *4 (D.N.J. June 12,

2023).

B

The District Court also granted Wayfair summary judgment as to Wraith’s claims

that the company retaliated against him for: (1) seeking workmen’s compensation

benefits, see N.J. Stat. Ann. § 34:15-39.1; and (2) using sick leave, see N.J. Stat. Ann.

§ 34:11D-4.

We will affirm because Wraith sets forth no facts tending to show that he was

“discharged in retaliation for making” his workmen’s compensation claim. Hejda v. Bell

Container Corp., 160 A.3d 741, 751 (N.J. Super. Ct. App. Div. 2017) (cleaned up).

Indeed, Wraith admitted that Wayfair “filed for Workmen’s Compensation benefits on

[his] behalf,” ensuring that he received his benefits. App. 144. Moreover, this case is

different from Cerracchio v. Alden Leeds, Inc., 538 A.2d 1292 (N.J. Super. Ct. App. Div.

1988), which Wraith cites to support his position. There, the employee was told: “if you

weren’t such a troublemaker you would still have a job here.” Id. at 1295. Wraith

identifies no comparable animus or suggestion that he was fired because he sought

workmen’s compensation benefits.3

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Galante v. Sandoz, Inc.
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924 A.2d 435 (Supreme Court of New Jersey, 2007)
Cerracchio v. Alden Leeds, Inc.
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Gilbert Wraith v. Wayfair Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gilbert-wraith-v-wayfair-inc-ca3-2024.