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A Better Partnership


Apr 2001
April 01, 2001

Job Rotation System Held Not an Essential Job Function

In Kiphart v. Saturn Corporation, the Sixth Circuit Court of Appeals recently upheld a jury's conclusion that Saturn's job rotation policy was not an essential job function. Saturn Corporation, GM's "different kind of car company," relied on a job rotation system in which workers were grouped into teams, each of which was responsible for one step of the automobile manufacturing process. Saturn claimed that all employees were required to be "fully rotational," meaning that they could perform all of the tasks assigned to the team, because team members were to rotate through all of the team tasks each day. The plaintiff was a disabled employee who was unable to perform a number of manual tasks, so that he could not perform all of the tasks on his team. After Saturn moved the plaintiff through a number of temporary positions, it eventually placed him on an involuntary disability leave. The plaintiff sued for disability discrimination under the ADA, and the jury found in the plaintiff's favor. The Sixth Circuit agreed that there was sufficient evidence to support the jury's verdict. After concluding that the plaintiff was "disabled" within the meaning of the ADA, it concluded that the ability to rotate among all tasks on a team was not an essential job function. The plaintiff presented evidence that Saturn never fully implemented the job rotation system, and that in many work teams employees did not fully rotate among tasks. In fact, the evidence suggested that the only time Saturn required full job rotation was with respect to employees with medical restrictions. Therefore, full job rotation was not an essential job function. The court then concluded that Saturn failed to reasonably accommodate the plaintiff, because there were a number of job openings he could have filled even though he was not fully rotational. In other words, Saturn could not require the plaintiff to be fully rotational when it did not require other employees to be fully rotational. The moral of the story is simple:  A job function is not an "essential" job function unless the employer requires its performance in practice, and not just in theory.

For more information, contact your WN&J attorney.

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