The Equal Employment Opportunity Commission filed a federal lawsuit against Sam’s Club, accusing the warehouse store chain of discriminatorily firing a disabled employee who tried to return to work from a medical leave of absence. The case demonstrates continued problems with disability accommodations in the workplace and enforces that employers are obligated to make reasonable accommodations for workers whatever the reason for an employee’s disability.
Case background and facts
Patrice Campbell Joseph, a senior Sam’s Club employee, was a victim of this case of discrimination when she was in a fatal car accident that left her with numerous disabilities. Post-concussion syndrome, upper back strain, muscle spasm, and chronic lower back pain were all the conditions that would need to be accommodated at work if she were to be able to work again.
Joseph attempted to return to her associate position at the Douglasville, Georgia, Sam’s Club store after taking an extended medical leave of absence in June 2022. She asked the EEOC to approve what the EEOC termed “minor, temporary adjustments to her job responsibilities” as an accommodation for her disabilities. She would have been able to work under such conditions with treatment for her medical issues.
The discrimination incident
The discrimination followed shortly after Joseph’s attempted return to work. After surviving one shift on the accommodations she required, her boss told her that she could not remain at work with any type of limitation. Rather, she was informed that she would have to take another leave of absence until such time that she could “work without any restrictions.”
At the request of her supervisor, Joseph requested further medical leave and gave Sam’s Club a definite date by which she would be capable of performing work without restrictions. The company refused the leave she requested and fired her. Most importantly, the store general manager unequivocally informed Joseph that Sam’s Club was not in a position to accommodate her injuries because their occurrence was off-work.
Legal violations and EEOC response
The EEOC sued (EEOC v. Sam’s East, Inc. and Walmart Inc., Case No. 1:25-CV-0222) in the U.S. District Court for the Northern District of Georgia on January 17, 2025. The federal government alleged that Sam’s Club discriminated against individuals with disabilities in hiring and thereby violated the Americans with Disabilities Act (ADA).
Marcus G. Keegan, an attorney with the EEOC’s Atlanta District Office, emphasized the underlying principle at issue: “The ADA requires accommodation of disabilities, no matter their cause.” He continued that “Sam’s Club had a duty to try to accommodate the employee’s disabilities when she tried to come back to work with partial limitations, but breached its duty when it refused to do so due to the cause of her underlying injuries.”
Darrell Graham, the district director of the Atlanta District Office of the EEOC, reaffirmed the agency’s commitment to disability rights: “Employees with disabilities have a right to work. The EEOC is committed to enforcing the ADA and ensuring that Americans with disabilities have equal access to employment”.
Legal significance and ADA requirements
This situation demonstrates a fundamental misconception that exists with some employers about disability accommodations. The reason for a disability is irrelevant in the law for determining an employer’s duty to provide reasonable accommodations. Whether an employee’s disability is caused by an on-the-job accident, car accident, medical condition, or other cause, employers are still obligated under ADA to participate in the interactive accommodations process.
The ADA mandates that employers do a reasonable accommodation that allows qualified employees with disabilities to do the job’s essential functions, except when it would be an undue hardship on the employer. The EEOC’s enforcement guidance states directly that employers must tailor each request for accommodation to the individual case and participate in an interactive process with the employee to find effective solutions.
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