Huber v Wal-Mart Stores Inc Case

Case Overview

• Case Name: Huber v. Wal-Mart Stores, Inc.

• Citation: 486 F.3d 480 (8th Cir. 2007)

• Judge: Circuit Judge Riley

• Key Question: Must an employer reassign a qualified disabled employee to a vacant position, even if not the most qualified applicant?

Background

• Pam Huber, a dry grocery order filler at Wal-Mart, suffered a permanent injury affecting her job.

• She sought reassignment to a vacant router position but was required to apply instead.

• A non-disabled person was hired, and Huber was later reassigned to a maintenance associate role at a lower wage.

Legal Proceedings

• Huber sued under the ADA for discrimination.

• Wal-Mart argued they followed a non-discriminatory policy and filed for summary judgment.

• The district court sided with Huber; Wal-Mart appealed.

Legal Standards Under ADA

To prove reasonable accommodation, Huber had to show:

1. Disability Status: A recognized disability under the ADA.

2. Qualified Individual: Possessing the necessary skills for the job.

3. Adverse Employment Action: Negative outcome due to disability.

Disputed Issues

• The dispute centered on whether the ADA mandates preference for qualified disabled employees in hiring.

Circuit Court Positions

• Tenth Circuit: In Smith v. Midland Brake, Inc., ruled in favor of disabled employees' reassignment.

• Seventh Circuit: In EEOC v. Humiston-Keeling, Inc., ruled reassignment does not require prioritizing disabled candidates.

Key Findings

• The ADA doesn’t serve as an affirmative action law; employers aren't required to prioritize disabled individuals over more qualified candidates.

• Wal-Mart provided reasonable accommodation by reassigning Huber, even if not to an ideal role.

Conclusion

• The district court's judgment was reversed, ruling in favor of Wal-Mart for adhering to their non-discriminatory policy.