Jarvis v Potter Case

Case Overview

• Case Title: Jarvis v. Potter, 500 F.3d 1113 (10th Cir. 2007)

• Circuit: 10th

• Judge: Hartz, Circuit Judge

• Background: Lanny Bart Jarvis was terminated from the United States Postal Service (USPS) due to safety concerns stemming from his post-traumatic stress disorder (PTSD).

Background Details

• Employment Start: Jarvis began working for the USPS in 1988 after being deemed fit for duty.

• PTSD Diagnosis: Diagnosed with PTSD in 1998 or 1999 while receiving treatment at a Veterans Affairs hospital.

• Job Positions: Worked as a mail handler and later transferred to a custodial position in 2001 to accommodate physical limitations related to war injuries.

• Request for Accommodations: Did not formally request accommodations related to his PTSD upon transferring to the custodial job.

PTSD-Related Incidents

• Incidents with Coworkers:

  • Cindy Frazier: Struck Frazier on two occasions when startled.

  • LesLee Bishop: Noted to be jumpy; informed Bishop of PTSD and desire for coworkers to announce their presence.

  • Al Nielsen Incident: Involved physical confrontation when startled; the situation escalated to the point where Jarvis acknowledged wanting to injure Nielsen.

Termination Process

• Administrative Leave: Following incidents, placed on administrative leave; later notified of being unfit for duty due to the potential risk to coworkers.

• Investigative Process: An internal investigation led by the Postal Inspector; interviews with coworkers and assessment of the incidents.

• Due-Process Meeting: Discussed worsening PTSD symptoms and inability to control reactions; he mentioned the possibility of a medical-disability retirement.

Key Findings

• Termination Letter: Cited history of violent reactions and the inability to accommodate his psychological condition without posing a risk.

• EEOC Standards: Direct threat defined as a significant risk of harm that cannot be mitigated by reasonable accommodations.

• ADA Definition: A qualified individual with a disability must be able to perform essential job functions with or without reasonable accommodation.

Appeal and Court Rulings

• Appeal Filed: Jarvis appealed the decision, claiming discrimination due to failure to accommodate his disability.

• Court's Ruling: Affirmed the district court's ruling; deemed Jarvis a direct threat to coworkers, which could not be reasonably accommodated.

  • Complete Reasoning: Evaluated incidents, including the subjective statements from coworkers about his conduct and the inherent risk associated with his PTSD symptoms.

Conclusion

• The court upheld the Postal Service's determination that Jarvis's violent reactions were a legitimate safety concern, affirming the summary judgment in favor of the Postal Service based on findings that he posed a direct threat in the workplace.