## Facts

- Anthony Mazzeo worked for Color Resolutions International, LLC (CRI) beginning in 2004, providing technical and sales service to customers in Florida and southern Georgia.
- In 2008, Mazzeo told CRI he had a herniated disc and torn back ligaments likely requiring surgery, including two weeks off work and activity restrictions for three to six months.
- On February 25, 2009, Mazzeo informed his supervisor that surgery was scheduled; on February 26, 2009, CRI began the process of terminating him.
- Mazzeo presented an affidavit from his physician stating the back impairment affected major life activities including walking, bending, sleeping, and lifting.
- Mazzeo also testified in a manner suggesting more limited effects (e.g., on golfing and sex), and the record was unclear whether that testimony described his pre- or post-surgery condition.
- CRI characterized the termination as part of a reduction in force.
- Mazzeo sued under the ADA, the ADEA, and the Florida Civil Rights Act (FCRA); the district court granted summary judgment for CRI, finding no prima facie disability case and applying a reduction-in-force framework to the age claims.

## Issues

1. Whether, under the ADAAA’s broadened definition of disability, Mazzeo produced sufficient evidence to create a genuine dispute that he had a disability for ADA and FCRA disability-discrimination claims.
2. Whether the district court used the correct prima facie framework for Mazzeo’s ADEA and FCRA age-discrimination claims, or improperly applied a reduction-in-force test.

## Decision

- The Eleventh Circuit vacated summary judgment for CRI and remanded on all claims.
- The court held that, in light of the ADAAA, Mazzeo’s medical evidence was sufficient to create a triable issue and to establish a prima facie case on his ADA and FCRA disability claims.
- The court held the district court erred by discounting the physician’s affidavit and relying heavily on unclear deposition testimony about recreational activities.
- The court held the district court erroneously applied the reduction-in-force prima facie framework to the ADEA and FCRA age claims.

## Legal Principles

- Under the ADAAA, “disability” must be construed broadly, and “substantially limits” is not intended to be a demanding standard.
- Medical evidence that an impairment limits statutorily recognized major life activities (including walking, bending, sleeping, and lifting) can be sufficient to create a genuine issue of material fact on disability status.
- On summary judgment, courts must draw reasonable inferences in favor of the nonmovant; an employer must show no genuine dispute of material fact and entitlement to judgment as a matter of law.
- The reduction-in-force prima facie framework is not automatically applicable; it is generally reserved for cases involving elimination of positions or classic layoff situations, and misclassification can improperly heighten a plaintiff’s prima facie burden.

## Conclusion

The Eleventh Circuit held that the ADAAA required a broader view of disability and that Mazzeo’s medical evidence was enough to reach a jury, and it further held that the district court applied an incorrect prima facie standard to the age claims by treating the case as a reduction in force.


Mazzeo v. Color Resolutions Int'l, LLC, 746 F.3d 1264 (11th Cir. 2014)