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Employment — disability discrimination — injunctions

United States Court of Appeals For the Seventh Circuit


Employment — disability discrimination — injunctions

An injunction to ensure compliance with the ADA has to have a time limit.

“In light of the evidence showing AutoZone’s intransigence at quite senior levels of management, we are satisfied that the district court did not abuse its discretion in ordering AutoZone to comply with the ADA’s reasonable accommodation requirement in the Central District of Illinois.”

“Nonetheless, even though the judge limited the geographic reach of the EEOC’s proposed obey-the-law injunction, the order has no temporal limit. It is permanent, which would permit any ADA accommodation claim arising at an AutoZone store in the Central District to be raised via contempt motion no matter how remote in time or different from the violation proven in this case. This would indefinitely deny AutoZone the protections of the normal administrative and adjudicative processes in that region. We are satisfied that AutoZone has earned this treatment for at least a reasonable time, or at least that the district court did not abuse its discretion in so finding, but we must remand to the district court with instructions to modify the injunction to impose a reasonable time limit on the first provision requiring compliance with the ADA.”

Affirmed and Remanded.

12-1017 EEOC v. AutoZone, Inc.

Appeal from the United States District Court for the Central District of Illinois, Gorman, Mag. J., Manion, J.

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