U.S. District Court of South Carolina
No. 2:05-2331-CWH, 2007 WL 2688608
September 10, 2007
Keywords: employment, interative process, reasonable effort, reassignment, state & local government
Facts of the Case
Mr. Rodney Prioleau was employed as a Mail Handler at the Charleston, South Carolina Processing and Distribution Center from 1981 to 2000. In February 2000, a co-worker kicked Mr. Prioleau in the buttocks, which caused lower back pain and soreness. After the incident, other employees allegedly harassed and humiliated him at work. Mr. Prioleau felt it had become a hostile work environment and stopped working at the facility in April 2000. His physician admitted him to an outpatient mental health program and diagnosed him with post-traumatic stress disorder, anxiety, and depression.
In August 2000, Mr. Prioleau was reassigned to limited duty janitorial duties at the East Bay USPS Station in Charleston. Shortly thereafter Mr. Prioleau fell off of a dock at the station, and as a result, his treating physician instructed him not to reach above his shoulder or lift more than 10 pounds. USPS thereafter made attempts to reassign Mr. Prioleau to a position that would accommodate his needs, but none of the options proved satisfactory for Mr. Prioleau, either because of job locations or his physical restraints. Without success, USPS ceased its efforts to accommodate him. Mr. Prioleau brought suit against John Potter, the Postmaster General of the USPS, in part alleging a violation of the Rehabilitation Act.
Issues of the Case
- Whether the USPS failed to engage in the interactive process and reassign Mr. Prioleau to an appropriate job to accommodate his disability.
Arguments & Analysis
1. Mr. Prioleau argued that the USPS discriminated against him on the basis of his degenerative disc impairment, post-traumatic stress disorder, and generalized anxiety by offering job reassignments that would require him to perform tasks exceeding his medical restrictions.
USPS asserted it was unable to reassign Mr. Prioleau to a position he was able to perform with or without accommodation, and Mr. Prioleau failed in his burden to identify such a position.
2. The court determined USPS engaged in an interactive process with Mr. Prioleau to reasonably accommodate his needs, but Mr. Prioleau refused all available positions, and there were no other positions available in Charleston at the same pay level that could accommodate Mr. Prioleau’s disability.
The court declared that USPS was only required to consider positions for Mr. Prioleau within the same grade or level as his previous position, and USPS had no duty to promote or create a position for Mr. Prioleau in order to accommodate his disability.
Mr. Prioleau failed to show that USPS’s inability to identify a position that could accommodate his needs was a result of their unwillingness to engage in the interaactive process. Rather, the court found that USPS did use reasonable effort in the interactive process to reassign him, but no such position was available, and thus no unlawful discrimination occurred.
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