Christopher Billesdon v. Wells Fargo Securities, LLC

Summary

The Fourth Circuit affirmed the jury's verdict on Billesdon's ADA retaliation claim, holding that a compressed termination timeline, changed treatment, and decision-makers' hostility after learning of his remote-work request let a reasonable jury find the request was the but-for cause of his discharge, and it affirmed the $14 million front-pay award. It reversed for judgment as a matter of law on the failure-to-accommodate claim, because Billesdon worked from home continuously after his request until discharge so an effective accommodation was already being provided and his termination-as-refusal theory belonged under 42 U.S.C. § 12112(b)(5)(B), which was neither pleaded nor submitted to the jury, and on the ADA and North Carolina disability-discharge claims, because the evidence showed retaliation for the protected act rather than discrimination because of disability. It vacated the punitive and emotional-distress damages, ordered remittitur of back pay to $4,225,558 absent a new damages trial, and remanded the prejudgment- and post-judgment-interest awards for determination under federal standards. Judge Berner concurred in the failure-to-accommodate judgment on narrower grounds but dissented from the disability-discrimination reversal and the back-pay remittitur, contending the majority failed to afford the jury's findings requisite deference.