Thomas Harwood, III v. American Airlines, Inc.

37 F.4th 954
CourtCourt of Appeals for the Fourth Circuit
DecidedJune 17, 2022
Docket20-2200
StatusPublished
Cited by8 cases

This text of 37 F.4th 954 (Thomas Harwood, III v. American Airlines, Inc.) 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
Thomas Harwood, III v. American Airlines, Inc., 37 F.4th 954 (4th Cir. 2022).

Opinion

USCA4 Appeal: 20-2200 Doc: 46 Filed: 06/17/2022 Pg: 1 of 15

PUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 20-2200

MAJOR GENERAL THOMAS P. HARWOOD, III,

Plaintiff - Appellant

v.

AMERICAN AIRLINES, INCORPORATED,

Defendant - Appellee.

No. 21-1137

Appeal from the United States District Court for the Eastern District of Virginia, at Alexandria. Liam O’Grady, Senior District Judge. (1:17-cv-00484-LO-JFA)

Argued: March 11, 2022 Decided: June 17, 2022

Before NIEMEYER and WYNN, Circuit Judges, and FLOYD, Senior Circuit Judge. USCA4 Appeal: 20-2200 Doc: 46 Filed: 06/17/2022 Pg: 2 of 15

Affirmed by published opinion. Judge Floyd wrote the opinion in which Judge Niemeyer and Judge Wynn joined.

ARGUED: Adam Augustine Carter, THE EMPLOYMENT LAW GROUP, PC, Washington, D.C., for Appellant. Jason Matthew Zarrow, O’MELVENY & MYERS LLP, Los Angeles, California, for Appellee. ON BRIEF: Andrew D. Howell, R. Scott Oswald, THE EMPLOYMENT LAW GROUP, PC, Washington, D.C., for Appellant. Anton Metlitsky, O’MELVENY & MYERS LLP, New York, New York, for Appellee.

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FLOYD, Senior Circuit Judge:

This case is back before us following a limited remand for a recalculation of

damages. We must now address Harwood’s appeal of the district court’s new orders on

damages, attorneys’ fees, and costs. Finding no abuse of discretion in the district court’s

new damages calculations and no clear error in the factual determinations on which it based

those calculations, we affirm its judgment. Under our extremely deferential review of the

district court’s fees determination, we likewise affirm.

I.

As relevant to this opinion, Major General Thomas Harwood, an Air Force reserve

service member and long-time American Airlines pilot, brought suit against American

Airlines pursuant to the Uniformed Services Employment and Reemployment Rights Act

(USERRA), 38 U.S.C. §§ 4301-35. 1 Under USERRA, military members returning from

service are entitled to reemployment in their civilian jobs if they meet certain criteria.

§ 4301. If entitled under § 4312, they are reemployed in accordance with stipulations set

forth in § 4313. See Butts v. Prince William Cnty. Sch. Bd., 844 F.3d 424, 430-31 (4th Cir.

2016). The default reemployment position, called the “escalator position,” is “the position

of employment in which the person would have been employed if the continuous

employment of such person with the employer had not been interrupted by [military]

1 The full factual background for this case is set forth in our prior opinion. Harwood v. Am. Airlines, Inc., 963 F.3d 408, 412-13 (4th Cir. 2020).

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service.” § 4313(a)(2)(A). If they incur a disability during their military service that would

not allow them to assume the escalator position, the employer must make reasonable

accommodations to help them qualify. § 4313(a)(3). Where such accommodations cannot

be made, the employer must reemploy them to a position of similar status. Id.

In his initial Complaint, filed in April 2017, Harwood claimed that American

Airlines violated USERRA, §§ 4312 and 4313, by delaying his reemployment and denying

him a pilot position after a qualifying period of military leave from June 2013 to August

2015. During that tour, Harwood was diagnosed with a heart condition and upon his return

experienced delays obtaining the necessary Federal Aviation Administration (FAA)

medical certification to return to his pilot position operating out of La Guardia Airport in

Queens, New York. Upon initial review at the beginning of September 2015, American

Airlines acknowledged that Harwood met the § 4312 conditions for reemployment but also

believed that it either needed to find another position for him under § 4313 or allow him to

use military convalescence leave until he could receive FAA clearance to fly.

After communicating this understanding to Harwood, American Airlines requested

that he advise them of a time to discuss reemployment options, but Harwood did not

immediately respond. On October 1, 2015, Harwood’s counsel requested reemployment

and suggested four alternate, non-pilot positions, including three with American Airlines’

Flight Department in Fort Worth, Texas. On October 22, 2015, American Airlines

extended two options to Harwood. First, because he was “currently unable to qualify for a

[FAA] First Class Medical certificate,” and therefore could not qualify to be a pilot,

American Airlines offered to extend his military leave, giving him time to seek the

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necessary FAA medical clearance with “reasonable assistance” from American Airlines. 2

J.A. 367. Alternatively, American Airlines offered to “reemploy him in the Flight

Technical Operations Group at the Flight Academy in [Dallas-Fort Worth], in a position

appropriate for his status.” J.A. 367. He would “be compensated at the same rate he would

receive if actively flying.” J.A. 367. Harwood declined both options but served several

more terms of military duty during the following months.

Harwood ultimately agreed to accept the above offered American Airlines position

in Fort Worth with a start date of January 25, 2016. However, on January 25, the FAA

finally granted his medical certificate. Harwood informed American Airlines and they

reinstated him as a pilot the next day. He went through his required pilot training, during

which time he received full pay as an American Airlines employee.

Reviewing Harwood’s initial complaint, the district court granted summary

judgment to Harwood, reasoning that under § 4312, Harwood should have been

reemployed on September 1 and that American Airlines’ failure to do so also violated

§ 4313. Harwood v. Am. Airlines, Inc., No. 1:17-cv-0484, 2018 WL 2375692, at *3-5

(E.D. Va. May 23, 2018). It granted summary judgment to American Airlines on

Harwood’s request for liquidated damages under USERRA, finding no evidence that

American Airlines had acted unreasonably and in bad faith. Id. Hearing Harwood’s

motion for reconsideration on the liquidated damages ruling, the court again denied

2 Service members convalescing from a disability incurred during their service may receive additional leave of up to two years under § 4212(e). The leave allowance does not impact the damages calculation.

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liquidated damages, but awarded back pay for September 1, 2015, to January 26, 2016, less

Harwood’s military pay during that time. Harwood v. Am. Airlines, Inc., No. 1:17-cv-

0484, 2018 WL 8803959, at *3 (E.D. Va. Aug. 20, 2018). The court found that American

Airlines’ October 22 job offer would not impact damages because it was a course-reversal

that failed to cure already-occurred USERRA violations. Id. Damages totaled $50,184.75.

Id. at *4. Harwood appealed, contending that the district court erred in determining that

the airline’s violations were not willful, in denying his request for injunctive relief, and in

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