Bedgood v. Waste Management Inc. – Do It For The Caselaw

Holding: The Eleventh Circuit affirmed the district court's grant of summary judgment because the plaintiff failed to present evidence that his termination was based on his disability.
Standard: Summary judgment standard under Federal Rule of Civil Procedure fifty-six
Vote: Per curiam opinion affirming the lower court's decision.
Practical effect: Employers may terminate employees for unexcused absences even when the employee has a disability, provided there is no evidence that the termination was motivated by the disability itself.

The Eleventh Circuit affirmed a district court's grant of summary judgment in an employment discrimination case brought under the Americans with Disabilities Act. The court found the plaintiff failed to provide evidence that his termination was motivated by his disability rather than his unexplained absences.

Background

Johnny Bedgood, Jr., a garbage truck driver, fell asleep at the wheel in July two thousand twenty due to obstructive sleep apnea. His employer granted him medical leave, but he subsequently missed multiple shifts citing childcare issues and then provided no explanation. The employer terminated him under its attendance policy for no-call, no-shows. Bedgood sued alleging disability discrimination under the Americans with Disabilities Act, but the district court granted summary judgment for the employer.

The court’s reasoning

The court reviewed the summary judgment de novo and applied the standard that a movant is entitled to judgment if there is no genuine dispute as to any material fact. The court noted that the plaintiff offered virtually no evidence of discriminatory intent. Bedgood conceded at his deposition that he had no evidence that his sleep apnea played a role in the employer’s decision. The court emphasized that the employer had accommodated his medical needs initially and that his termination was based on his frequent and unexplained absences rather than his disability.

What it means going forward

Employers may terminate employees for unexcused absences even when the employee has a disability, provided there is no evidence that the termination was motivated by the disability itself.