In the case of Sutherland v. Peterson's Oil Service, Inc., Jesse Sutherland, an oil service technician, alleged that his employer, Peterson's Oil Service, Inc., engaged in disability discrimination and retaliation under the Americans with Disabilities Act (ADA) and Massachusetts state law. Sutherland sustained a knee injury two months into his employment, leading to a torn meniscus and damaged patella. He requested reduced work hours due to his injury and subsequently took a 12-week leave for knee surgery. Upon his intended return in April 2020, he was informed of his termination, effective the date he was supposed to return, citing a lack of work during the COVID-19 pandemic. 

Sutherland filed a lawsuit alleging disability discrimination, retaliation for accommodation requests, and wrongful termination. The district court granted summary judgment in favor of Peterson's, concluding that Sutherland did not provide sufficient evidence to establish a prima facie case of disability discrimination, particularly questioning whether his knee injury qualified as a disability under the ADA. citeturn0search0

Upon appeal, the United States Court of Appeals for the First Circuit vacated the district court's summary judgment on Sutherland's disability-related claims and remanded the case for further proceedings. The appellate court concluded that Sutherland provided sufficient evidence to show that his knee injury was a disability under the ADA, as it substantially limited his major life activities. The court also found that Sutherland's requests for reduced work hours were reasonable and that Peterson's failed to engage in the interactive process required by law. However, the court affirmed the district court's decision regarding Sutherland's wrongful termination claim based on an alleged violation of Massachusetts public policy, as Sutherland did not provide sufficient evidence of a well-defined public policy supporting his views on biofuel. 

This case underscores the importance of employers engaging in the interactive process to determine reasonable accommodations for employees with disabilities and highlights that temporary injuries can qualify as disabilities under the ADA, thereby expanding the scope of protection for employees undergoing medical treatment. 

If you have been injured at work in Bergen County, Hudson County, Essex County, Morris County or Union County, call the Khorozian Law Group, for a free consultation at (201) 944-9200.

See the full Case Ruling for Sutherland v. Peterson's Oil Service, Inc. on Justia (link),  Case Mine (here), and Google Scholar (link)