Judge: Former employee cannot sue twice over same injury

By D.M. Herra | Mar 4, 2019

The U.S. District Court - Eastern District of Louisiana dismissed a lawsuit filed against rental giant Aaron’s Inc. by a former employee, finding that she already settled with the company in a previous action and agreed to waive any further liability.

According to court documents, Harmony V. Peddy was hired by Aaron’s, which rents furniture and appliances to the public, in 2000 as a divisional sales manager. In 2009, a 50-pound beam fell on Peddy’s head while she was working in a store in New Iberia, resulting in permanent disabilities.

At first, Peddy said, the company accommodated her disabilities, allowing her extra time to complete some tasks and permitting her to delegate others. But when a new supervisor was hired to oversee Peddy’s position, she said, he began removing her accommodations. The quality of her work suffered and she was fired in 2016. In 2018, Peddy filed a suit claiming discrimination on the basis of her disability, hostile work environment and failure to accommodate her disability in violation of the Americans with Disabilities Act. She also sought damages under state law for intentional infliction of emotional distress.

The court granted Aaron’s motion to dismiss and counterclaim. According to the company, the day after Peddy filed her lawsuit—before it had been tendered to the defendant—she entered into a settlement with Aaron’s on a workers' compensation claim over the accident that led to her injury. Several weeks later, she signed an agreement releasing Aaron’s from “all liability of any nature whatsoever” arising out of the workplace accident.

Peddy responded that the settlement pertained only to the workers' compensation claim and did not prevent her from bringing suit for wrongful termination in violation of the ADA.

The court disagreed. In her analysis of the contract, U.S. District Judge Sarah S. Vance found the release Peddy signed clearly releases Aaron’s from any liability. It specifically lists wrongful termination as a result of the injury among the actions for which the company is not liable.

“Peddy’s disability discrimination and tort claims plainly arise ‘as a result of’ her injuries … because she frames her injuries as a ‘but-for’ cause of her claims,” Vance wrote. “She alleges that the accident caused her to suffer ‘permanent disabilities’ and that defendant created a hostile work environment and discriminated against her because of her disabilities. The release therefore covers the claims Peddy brings in this lawsuit.”

The court also found Peddy had breached her contract with the company by maintaining the lawsuit after signing the release. It awarded Aaron’s attorney’s fees and court costs.

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