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Garland's Digest
on employment discrimination law
online since 1997
 

 

Disclaimer: The case on which this summary is based may no longer be current law. Also, if the case was decided on summary judgment, the court recited the "facts" in the light most favorable to the non-movant, which may not be the true facts.

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Matczak v. Frankford Candy and Chocolate Co., 136 F.3d 933 (3d Cir. November 18, 1997)

Keywords: ADA (disability, corrective measures, epilepsy, regarded as disabled; element of prima facie case)

Introduction: Joseph Matczak sued his former employer, Frankford, under the ADA after he was terminated.  The district court granted summary judgment on behalf of Frankford.  The Third Circuit reverses and remands.

Facts: Matczak was a maintenance supervisor.  In November 1993 he suffered an epileptic seizure and was hospitalized for seventeen days.  He had been diagnosed with epilepsy thirty years earlier, but it had always been controlled by medication.

Matczak's doctor placed certain work restrictions on him for the next  5½ months.  In April of 1994, Frankford fired Matczak.  Two conflicting explanations were given:  (1) poor work performance; and (2) job eliminated due to lack of work.

Law:

1. Disability
   1. The Third Circuit holds that the district court erred in determining that Matczak was not disabled because his medication controls his epilepsy and because his work restrictions were only for 5 ½ months.
   2. Based upon the legislative history and EEOC Interpretative Guidelines, corrective measures (such as medication) should not be taken into account. Furthermore, even though the work restrictions were only for 5.5 months, the epilepsy was permanent.
   3. The Third Circuit is not holding that Matczak is disabled -- just that there is a jury question.
2. Regarded As Disabled
   1. The district court found that there was sufficient evidence to create a jury question that Matczak was regarded as disabled; but he failed to establish two elements of a prima facie case: (1) that he was meeting the legitimate expectations of his employer; and (2) that persons outside the protected class were treated more favorably.
   2. The Third Circuit recognizes the flexibility of the elements of the prima facie case:  It lists the following as the general elements of a prima facie case:
      1. the plaintiff is a member of a protected class;
      2. the plaintiff was qualified for the job;
      3. the plaintiff was terminated despite those qualifications; and
      4. after the termination, the job remained open and the employer sought applicants with the plaintiff's qualifications.
   3. With respect to job qualifications, at the prima facie stage, the district court should limit its inquiry as to whether the employee meets the objective qualifications for the position (such as educational requirements); and not assess whether the employee was meeting the subjective expectations of the employer.
   4. With respect to a requirement to show that others are treated more favorably, the Third Circuit points out that this is an alternative element to the usual fourth element.  Since it is only an alternative, it was not required in this case.
3. Therefore, the Third Circuit reverses and remands the ADA claims.
4.  Click here to see actual case.