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Rehrs v. The Iams Company

United States Court of Appeals for the Eighth Circuit

486 F.3d 353 (8th Cir. 2007)

Relevant factsFree

Rehrs (plaintiff), a Type I diabetic warehouse technician at Iams (defendant), worked a fixed evening shift for two years until the company (after being acquired by Procter & Gamble) switched to a rotating schedule of alternating 12-hour day and night shifts for all technicians. After suffering a heart attack, Rehrs asked to return to a fixed daytime schedule to help manage his diabetes; the company granted this for 60 days but then said shift rotation was an essential job function and could not be made permanent. Rehrs sued under the Americans with Disabilities Act (ADA), and the district court granted the company summary judgment, reasoning that even if Rehrs's diabetes qualified as a disability, he could not perform the essential rotating-shift duty.

IssueFree

Whether adverse employment decisions against individuals who cannot perform essential job functions, with or without reasonable accommodation, violate the ADA.

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