Mark Granas v. Union Pacific Railroad Company

Summary

The court denied Union Pacific Railroad Company's post-trial motion for judgment as a matter of law or, alternatively, a new trial in Mark Granas's disability-discrimination action under the ADA and Oregon law. The court upheld the jury's findings that Granas was a qualified individual and that Union Pacific used an unlawful screening policy, and declined to alter the $25 million punitive-damages award.

Holdings

1. Union Pacific was not entitled to judgment as a matter of law because the trial evidence provided more than one reasonable basis for the jury to find that Granas was a qualified individual who could perform the essential functions of his job.
2. Union Pacific was not entitled to judgment as a matter of law because the jury could reasonably find that its blanket shoulder-dislocation policy was discriminatory and that Union Pacific failed to prove that the policy was job-related and consistent with business necessity.
3. Union Pacific was not entitled to a new trial because the verdict was not contrary to the clear weight of the evidence, was not shown to rest on false or perjurious evidence, and did not result in a miscarriage of justice.
4. Union Pacific was not entitled to a new trial on punitive damages because it did not show manifest error of law, manifest error of fact, or newly discovered evidence.
5. The $25 million punitive-damages award did not warrant alteration under Rule 59(e) because Union Pacific failed to demonstrate newly discovered evidence, clear error, or an intervening change in controlling law.

Questions Presented

1. Whether Union Pacific was entitled to judgment as a matter of law because no reasonable jury could find that Granas was a qualified individual able to perform the essential functions of his job.
2. Whether Union Pacific was entitled to judgment as a matter of law on its business-necessity defense to Granas's unlawful-screening claim.
3. Whether Union Pacific was entitled to a new trial on the merits because the jury's verdict was against the clear weight of the evidence or otherwise unfair.
4. Whether the Court's punitive-damages determination should be set aside or retried for lack of evidentiary support or manifest error.
5. Whether the $25 million punitive-damages award was excessive and whether the judgment should be altered under Rule 59(e).

Disposition

other