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Record retention is complex and time consuming. However, in addition to complying with various federal and state laws, keeping good, well-organized records can be very helpful in documenting and supporting an organization’s employment actions.
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This special report will discuss how you can ensure your records are in good order, and establish a record-retention policy.

Topics covered:
1. Hiring Records
2. Employment Relationships
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5. Electronic Information Issues
6. Tips for Better Recordkeeping
7. A List of Legal Requirements

Make sure you have the information you need to know to keep your records in order.

April 01, 2002
Diabetic Has Qualified Disability Under ADA

By LINDA TRAINOR
Contributing Editor, Best Practices in HR

Key Issue: Is diabetes a qualified disability under the Americans with Disabilities Act (ADA)? It depends.

The Case: Nawrot v. CPC International, n/k/a Bestfoods, Inc., 7th Circuit, No. 00-2849 (January 2002)

Ralph Nawrot worked for Bestfoods for over 20 years. For 15 of those years he was a warehouse supervisor. However, in 1995 he began having interpersonal relationship problems, which he construed as misunderstandings. Finally, following an incident where Nawrot refused to shake a new employee's hand, he was given a formal reprimand and a final warning that similar future conduct would result in his termination.

At the same time, his long-time friendship with a female co-worker was falling apart. Various rumors (including that Nawrot was stalking and soliciting sex from her) began circulating around the company. The woman had been terminated by the company, but with Nawrot's and her union's help was reinstated.

Employee's Poor Behavior
Does Not Absolve Company

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Just because Nawrot was a diabetic did not automatically qualify him as disabled under the ADA. However, the seriousness of his condition required extraordinary monitoring and insulin injections. Even diligent attention didn't eliminate all the adverse effects of his diabetes. His episodes were unpredictable, affected his ability to think coherently, function normally and presented a significant risk of death.

Reviewing these and other related impairments, the 7th Circuit disagreed with the district court's conclusion saying, "& we are convinced that Nawrot has sufficiently demonstrated that his diabetes substantially limits his ability to think and care for himself, which are both major life activities." The court also concluded that Nawrot's allegations that Bestfoods had failed to reasonably accommodate his disability and discriminated against him because of his disability had not been fully addressed. So this part of the case was sent back to the district court for further review.

The 7th Circuit did uphold the district court's decision with respect to Nawrot's retaliatory termination claim. It said, "After numerous documented occasions of inappropriate behavior, Bestfoods demanded that Nawrot straighten up and fly right and instead he crashed and burned."

Experts remind employers that even if an employee's behavior is grounds for termination, that doesn't absolve the company from its responsibilities with regard to discrimination practices.

When she returned to work, the company asked both of them to stay away from each other. Nawrot did not comply. The woman filed a complaint. The company investigated and terminated him for insubordination, harassment, and disloyalty.

Nawrot's version

Nawrot viewed the termination differently. Nawrot is a Type I diabetic and must inject himself with insulin approximately three times a day and test his blood-sugar level at least 10 times a day. Even if he follows this regimen, he can experience episodes of high or low blood sugar, which adversely affect his health, personality, and behavior and can be life threatening.

As his condition worsened, Nawrot asked for permission to take more breaks to better monitor his blood sugar. The company allegedly denied all of the requests. Finally, he requested a leave of absence, which was approved.

About two months later, with his doctor's approval, Nawrot asked to return to work. The company did not approve his return until two months after his request. During his leave, Bestfoods posted signs with plant security informing them to keep Nawrot from entering the plant and told employees that he was away for psychological reasons.

When he returned to work, Nawrot again requested discretion to monitor his diabetes, but his request was denied. Continued efforts for accommodation fell on deaf ears. Finally, after returning from vacation, he was fired. He filed suit alleging, among other things, failure to accommodate and discrimination under the ADA. He also alleged that his termination was retaliatory, a further violation of the ADA and Title VII of the Civil Rights Act.

The district court found in favor of Bestfoods, holding that Nawrot had not shown he was a qualified individual with a disability and had failed to show that the reasons for his termination were a pretext for discrimination. Nawrot appealed.

The 7th Circuit Court of Appeals concluded that Nawrot had "... sufficiently demonstrated that he is a qualified individual with a disability under the ADA...." While the 7th Circuit said Nawrot didn't provide enough evidence to show that the stated reason for his termination was pretext, it did believe that his claims of failure to accommodate and discrimination warranted further exploration.

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