In Qulies-Quiles v. U.S. Postal Service, 439 F.3d 1 (1st Cir. 2006), the First Circuit Court of Appeals reinstated a jury award of $300,000 for a postal worker whose supervisors harassed him because they believed that he had a mental disability. Following is the account of the events given in the court opinion:
- Genaro Quiles-Quiles began working for the U.S. Postal Service in 1986 as a mail carrier. In 1995 he began working as a window cashier. From the beginning of his employment, Quiles’ immediate supervisor, Doris Vasquez, frequently interfered with his handling of the cash drawer and his work with customers. Because he would be ultimately responsible for any inconsistencies in his cash drawer, Vasquez’s conduct made Quiles anxious and nervous.
- In October 1997, Vasquez screamed at Quiles in front of customers and co-workers for allegedly taking lunch without authorization. Immediately after this incident, Quiles suffered from a panic attack, missed three days of work and had to seek psychiatric therapy for anxiety and depression. Upon his return to work, Quiles presented his second-level supervisor, Virgilio Lopez, with a certificate from his psychiatrist explaining his absence. After he returned from work, Vasquez interrupted Quiles more frequently. Despite his complaints regarding Vasquez’s behavior, management did not intervene. In March of 1998, Vasquez “drove at’ Quiles with her car; Quiles reported this incident to the local police, as well as to his employer. After this incident Quiles’ medical condition worsened, and he entered a state of acute anxiety.
- Because Quiles’ medical condition was worsening, his psychiatrist recommended that he take one week of leave and that he not return to his cashier duties. When Quiles returned from his week of leave, he submitted medical documentation referencing this recommendation to Lopez in a sealed envelope. Lopez shared this information with Vasquez, who read it and laughingly stated that Quiles was crazy; Lopez was in the presence of Vasquez at the time, and he laughed also. After this, Vasquez and Lopez called Quiles crazy on a daily basis and joked in front of his coworkers about Quiles’ medication and psychiatric treatment. Lopez also made comments regarding Quiles being a danger to the workplace.
- The harassment and derogatory comments intensified after Quiles filed an EEO complaint. As a result, Quiles condition worsened, and in March 2000 he was hospitalized for several days for severe depression and took a leave of absence from work. Quiles returned to work in 2001, but only worked until August of 2003, when an incident with Vasquez triggered a relapse of his depression and required hospitalization.
After hearing all of the evidence in this case, the jury returned a verdict in favor of Quiles and awarded him $950,000 in compensatory damages, which the district court reduced to the statutory limit of $300,000. The Postal Service filed a post-trial motion for judgment as a matter of law, asking the district court to set aside the jury verdict. The district court rejected the jury’s disability-harassment finding because Quiles had not established that he was disabled. The district court also rejected the jury’s retaliation finding because Quiles had failed to prove either that he was subjected to a hostile work environment or that there was a causal nexus between the harassment and his filing of an EEO complaint.
The First Circuit Court of Appeals reviewed the district court’s decision and disagreed, reinstating the verdict and the award of $300,000.
The Court of Appeals found that there was sufficient evidence to find that Quiles was perceived by the Postal Service as being disabled because his supervisors believed that his mental impairment substantially limited his ability to work. Citing Supreme Court precedent, the Court of Appeals noted that the purpose of protecting those who are perceived as disabled is to prohibit employers from relying on precisely this type of stereotypical assumption about an individual’s ability. The Court of Appeals found that there was evidence that Quiles’ supervisors thought his mental impairment made him a potential safety risk to his coworkers. The Court of Appeals stated that the belief that the mentally ill are disproportionately dangerous is precisely the type of discriminatory myth that the Rehabilitation Act and the Americans with Disabilities Act were intended to confront. Additionally, the Court of Appeals held that these remarks suggest a shared belief that Quiles’ disability would preclude him from holding most jobs in our economy and would thus render Quiles substantially limited in the ability to work.
The Court of Appeals also found that Quiles was subjected to daily harassment because of his disability. The Postal Service acknowledged that Quiles was subjected to daily ridicule regarding his mental impairment but defended this conduct by stating that it was common in blue-collar workplaces. The Court of Appeals rejected the Postal Service’s “blue-collar” defense and found that a reasonable jury could find that the ridicule was sufficient to constitute a hostile work environment. The Court of Appeals also rejected the Postal Service’s alternate defense that Vasquez did not harass Quiles because of his disability, noting that some of the harassment occurred before Vasquez was aware of Quiles’ disability. The Court of Appeals held that even without the initial harassment, there was ample proof that Quiles was subsequently harassed because of his disability. Finally, the Court of Appeals also held that there was sufficient evidence that Quiles was subjected to retaliation, as the harassment was markedly more intense after Quiles filed his EEO complaint.
Society’s myths and fears about disabilities are sometimes as handicapping as the actual limitations that caused by medical or mental health conditions. For disabled federal employees this decision affirms the Rehabilitation Act’s prohibition of harassment of handicapped employees. For non-disabled federal employees who suffer from medical or mental health conditions, this decision reinforces the Rehabilitation Act’s protections against employers acting on reliance of stereotypes about an employee’s abilities.
This information is provided by the attorneys at Passman & Kaplan, P.C., a law firm dedicated to the representation of federal employees worldwide. For more information on Passman & Kaplan, P.C., go to http://www.passmanandkaplan.com.
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