Jay Hannah v. UPS

72 F.4th 630
CourtCourt of Appeals for the Fourth Circuit
DecidedJuly 10, 2023
Docket21-1647
StatusPublished
Cited by11 cases

This text of 72 F.4th 630 (Jay Hannah v. UPS) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jay Hannah v. UPS, 72 F.4th 630 (4th Cir. 2023).

Opinion

USCA4 Appeal: 21-1647 Doc: 34 Filed: 07/10/2023 Pg: 1 of 15

PUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 21-1647

JAY HANNAH,

Plaintiff - Appellant,

v.

UNITED PARCEL SERVICE, INC.,

Defendant - Appellee.

Appeal from the United States District Court for the Southern District of West Virginia, at Charleston. Joseph R. Goodwin, District Judge. (2:20-cv-00120)

Argued: January 26, 2023 Decided: July 10, 2023

Before NIEMEYER, RUSHING, and HEYTENS, Circuit Judges.

Affirmed by published opinion. Judge Niemeyer wrote the opinion, in which Judge Rushing and Judge Heytens joined.

ARGUED: Hoyt Eric Glazer, GLAZER SAAD ANDERSON, LC, Huntington, West Virginia, for Appellant. Richard M. Wallace, LITTLER MENDELSON, P.C., Charleston, West Virginia, for Appellee. ON BRIEF: Kameron Miller, LITTLER MENDELSON, P.C., Charleston, West Virginia, for Appellee. USCA4 Appeal: 21-1647 Doc: 34 Filed: 07/10/2023 Pg: 2 of 15

NIEMEYER, Circuit Judge:

When Jay Hannah, a package delivery driver for United Parcel Service, Inc.

(“UPS”), injured his hip and buttocks, he requested that he be allowed to drive his route

with a smaller truck that would have a softer suspension or, alternatively, that he be

assigned to an “inside job.” Because UPS had determined that the route that Hannah had

been driving required a larger truck and there were no openings for inside work at the time,

UPS instead accommodated Hannah by allowing him to take an unpaid leave of absence

until his hip and buttocks healed and he could return to work.

Hannah commenced this action under the Americans with Disabilities Act of 1990

(“ADA”), 42 U.S.C. § 12101 et seq., alleging that UPS’s refusal to provide him with the

accommodations he requested violated his rights under the ADA. The district court granted

summary judgment to UPS, concluding, as a matter of law, that Hannah had not shown that

the accommodations he requested were reasonable and that Hannah’s unpaid leave of

absence constituted a reasonable accommodation in the circumstances.

For the reasons given herein, we affirm.

I

Hannah, who had been a UPS employee in Parkersburg, West Virginia, since 2008,

began experiencing pain in his lower back, hip, and buttocks in December 2017. His

condition was then diagnosed as hip bursitis. At the time, Hannah was assigned to a

delivery route, for which he had bid under the governing collective bargaining agreement

and which, as UPS had determined, required him to drive a truck with a 600-cubic-foot

2 USCA4 Appeal: 21-1647 Doc: 34 Filed: 07/10/2023 Pg: 3 of 15

capacity to carry all the packages to be delivered on his route. That size truck, however,

had a stiff suspension, which made for a rough ride that aggravated Hannah’s injury. After

UPS accommodated his request for a better padded seat, he still could only work

sporadically until October 2018. At that time, his physician diagnosed him with sacroiliitis

and cleared him to return to work, so long as he avoided prolonged sitting until November

1, 2018. Hannah then made a request to UPS for an accommodation under the ADA to

provide him with a smaller vehicle, a van with a cargo capacity of 300 to 400 cubic feet,

which would have a softer suspension and thus would provide him with an easier ride.

Alternatively, he requested assignment to an “inside job” within a 30-mile radius for which

he was qualified until he could return to his route.

UPS officials met with Hannah and then conferred among themselves and

determined that UPS could not provide Hannah with the smaller vehicle he had requested

because such a van would have an insufficient capacity to serve his route. Thus, providing

Hannah with such a van would require either that Hannah give a part of his route to another

driver or that Hannah himself complete the route in multiple trips. UPS found neither

option to be feasible, as each would violate the governing collective bargaining agreement.

With respect to inside work, UPS advised Hannah that it had no openings at the time, but

it would consider him for any such opening when it occurred. While UPS thus denied

Hannah the particular accommodations he requested, it did allow him to retain his job and

take leave without pay until he could return to work. And after several months, Hannah

did return to work, continuing to drive the route to which he was assigned in a truck suited

for that route.

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After returning to work, Hannah commenced this action against UPS under the

ADA for its failure to provide him with either of the accommodations that he requested.

The district court granted UPS’s motion for summary judgment, concluding that Hannah

failed to carry his burden of demonstrating that he could perform the essential functions of

his job with the accommodations requested. The court also concluded that the leave of

absence that UPS provided was in fact a reasonable accommodation, even though not one

that Hannah had requested.

This appeal followed.

II

The issue in this case turns on whether Hannah, who was temporarily disabled,

requested a reasonable accommodation under the ADA and whether UPS, in providing a

different accommodation that was not requested by Hannah, complied with its duties in

response to Hannah’s request.

The record shows that because of his hip and buttocks condition, Hannah was unable

to drive the 600-cubic-foot truck provided to him for delivering the route’s packages

because the truck’s stiff suspension resulted in too harsh a ride. He requested that UPS

provide him with a 300- to 400-cubic-foot van, which had a softer suspension and which,

he claimed, would enable him to drive his route. Hannah acknowledged that the smaller

van would need to hold all of the packages for delivery on his assigned route. He also

stated that he was not sure that such a van would be able to hold all of the packages because

“I’ve never got a chance to try it out.” But he agreed that if such a van could not

4 USCA4 Appeal: 21-1647 Doc: 34 Filed: 07/10/2023 Pg: 5 of 15

accommodate all of the packages, his request would require that he “displace somebody

from another route,” implicating the collective bargaining agreement. Alternatively, he

requested “an inside job,” such as washing vehicles or sorting packages.

UPS rejected Hannah’s requests. In defending its position, UPS explained that

delivery routes were assigned to drivers based on seniority and their bids for the routes, as

provided by the collective bargaining agreement. And the size of vehicle assigned to each

route was based on the expected volume of packages for that route. Thus, a 600-cubic-foot

truck was assigned to Hannah’s route because UPS had determined that that was the size

of truck that the route required. In addition, UPS noted that the collective bargaining

agreement restricted drivers to working no more than 9.5 hours per day. In light of these

restrictions, it explained that a 300- to 400-cubic-foot van would not be able to service

Hannah’s route — Hannah “would have . . . [to] put [work] on another driver or drivers . . .

[w]hich potentially would put them over 9.5 hours dispatched; [and] they are protected

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