Court: AutoZone Can’t Confine ADA Suit Over Attendance “Points” System to Three Stores

AutoZone cannot limit the scope of an Americans With Disabilities Act lawsuit to just three of its retail stores, but instead will have to defend against the alleged ADA violation at all of its stores, a federal district court ruled on Nov. 6.

The case centers on the auto parts company’s alleged policy of assessing employees attendance “points” for absences, without permitting any general exception for disability-related absences. In a lawsuit filed against the company in 2014, the EEOC alleged that the policy, at least from 2009 to 2011, caused the firing of qualified employees with disabilities with even modest numbers of disability-related absence, in violation of Title I of the ADA.

The district court rejected the company’s argument that EEOC did not conduct an adequate, “nationwide” investigation prior to filing suit.  The company requested that the suit be limited to just three of the company’s many retail stores as a result.  According to its website, the company operates several thousand stores in 48 states and Puerto Rico.

“[T]he Court may not inquire into the sufficiency of the EEOC’s pre-suit investigation in order to ‘limit’ the scope of the litigation,” the court stated in its order, which was written by U.S. District Judge Robert M. Dow, Jr.  The order also cited the recent decision in Mach Mining, LLC v. EEOC, in which the Supreme Court stated that courts should not impose additional procedural requirements on such litigation beyond those established by Congress.  The order explained, “this Court would be imposing extra procedural requirements if it required the EEOC to offer additional proof that ‘its investigation was … conducted on a nationwide basis.”

For more information on the lawsuit, click here.

Here’s more information on the Mach Mining ruling.

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