## Facts

- Genaro Quiles-Quiles worked for the United States Postal Service (USPS) and transferred in 1995 to a window cashier position at the Bayamon Gardens station.
- His immediate supervisor, Doris Vázquez, repeatedly interfered with his customer service and cash-handling tasks, making him anxious about being blamed for errors.
- On October 4, 1997, Vázquez publicly screamed at him after a lunch-related dispute; Quiles suffered a panic attack, sought psychiatric treatment for anxiety and depression, and missed several days of work.
- Quiles returned with medical documentation supporting his absence and continued complaining to supervisory officials, but management did not stop the conduct.
- A jury could find that on March 5, 1998, Vázquez drove her truck toward Quiles in a threatening manner outside the post office; he reported the incident to management and police.
- Quiles’s psychiatrist recommended leave and reassignment; Quiles provided medical documents to supervisor Virgilio López in a sealed envelope.
- López opened the sealed envelope and shared the medical information with Vázquez; supervisors then mocked Quiles’s mental health, called him “crazy,” and joked about his medication and need for psychiatric care.
- Quiles filed an administrative complaint alleging disability-based harassment; he claimed the ridicule and hostility continued and escalated after his complaints.
- Quiles’s condition worsened; his psychiatrist eventually deemed him totally disabled, he took multiple leaves, and he was hospitalized twice.

## Issues

1. Whether the evidence permitted a reasonable jury to find a disability-based hostile work environment under the Rehabilitation Act.
2. Whether the evidence permitted a reasonable jury to find retaliation for protected complaints (internal complaints and an administrative discrimination charge).
3. Whether the district court properly granted judgment as a matter of law after a plaintiff’s jury verdict, given the Rule 50 standard and the requirement to view evidence and inferences favorably to the verdict.

## Decision

- The court of appeals reversed the district court’s grant of judgment as a matter of law for USPS.
- The court held the evidence was sufficient for a reasonable jury to find disability-based harassment that was severe or pervasive and occurred because of Quiles’s mental impairment.
- The court held the evidence was sufficient for a reasonable jury to find retaliatory conduct following Quiles’s protected activity.
- The court reinstated the jury’s verdict and damages award as reduced to the statutory cap of $300,000.

## Legal Principles

- The Rehabilitation Act applies ADA substantive standards to federal employment discrimination and retaliation claims.
- A disability-based hostile work environment requires proof that harassment was because of disability and sufficiently severe or pervasive to alter the conditions of employment and create an abusive environment (objectively and subjectively).
- Disclosure or misuse of confidential medical information, coupled with ridicule tied to a mental impairment, can support an inference that harassment occurred because of disability.
- Retaliation requires protected activity and materially adverse treatment (including retaliatory harassment) that could deter a reasonable worker from complaining, plus a causal connection that may be inferred from timing and escalation.
- Post-verdict judgment as a matter of law is improper if, viewing the evidence and reasonable inferences favorably to the verdict, a reasonable jury could find for the nonmoving party; the court may not reweigh evidence or credibility.

## Conclusion

The First Circuit held that evidence of supervisors’ disclosure of psychiatric information, disability-focused mocking, threatening conduct, and escalating hostility after complaints could support jury findings of a severe or pervasive disability-based hostile work environment and retaliation under the Rehabilitation Act, requiring reinstatement of the capped damages award.


Quiles-Quiles v. Henderson, 439 F.3d 1 (1st Cir. 2006)