In 2010, Douglas Rider—the lead carpenter at the Lincoln County School District—injured his back while performing a district roofing project.
In April 2011, a neurosurgeon performed surgery on Rider’s back. A few days later, he released Rider with orders limiting him to lifting no more than five pounds, and to performing repetitive activity for no more than two hours.
In August, the doctor increased his lifting restriction to 50 pounds.
When Rider returned to work in September, he asked for assistance in lifting over 50 pounds. The district replied that the accommodation was unreasonable and asked Rider to have his doctor fill out a questionnaire assessing his ability to perform certain essential job functions.
Rider refused that request and instead presented the district with a new work release from his doctor that indicated a permanent work restriction of not lifting or carrying more than 50 pounds.
Eight months later, he presented the district with a report from his doctor dated May 30, 2012, stating that Rider had no workplace restrictions if he wore a back brace and used common sense.
Rider returned to work without accommodations. However, he requested assistance in September because his back was hurting.
In October, Rider refused the district’s request to submit to a fitness-for-duty evaluation by another doctor. That same month, the district communicated to Rider that it would not accommodate him unless he provided a medical opinion specifying appropriate restrictions.
Instead of providing such a report, Rider filed a suit against the district claiming that it had violated the Americans with Disabilities Act by failing to engage in a good-faith interactive process.
The defendant filed a motion for summary judgment.
EMPLOYER WINS [put arrow here]
District Judge Ann Aiken ruled that an employee was not entitled to refuse to provide information critical to a meaningful interactive process and then later protest that he was unfairly deprived of accommodations. She also held that an employee could not refuse to provide reasonable medical documentation of his need for accommodations when requested by the employer.
The judge decided that the district’s request for an opinion from Rider’s doctor—and also its request for an independent medical examination—were reasonable, and that Rider had no right to refuse either of them.
Judge Aiken held that the full work release from Rider’s doctor in May 2012 established that he no longer required accommodations to perform the essential functions of his job. Ruling that the district’s requests for more detailed explanations of how his disability would impact his ability to perform essential job functions constituted a good-faith effort to seek reasonable accommodations, she decided that Rider’s failure to provide responsive information was fatal to his claim since there was no further information from any other experts about any workplace restrictions.
She granted summary judgment in favor of the district.
[Rider v. Lincoln County School District, U.S. District Court for the District of Oregon, No. 6:13-cv-02299, 02/24/15].