Takeaway: Million-dollar jury verdicts in equal employment opportunity cases may be subject to large reductions due to federal caps on compensatory and punitive damages. However, some state law damages are uncapped.

A former railroad foreman successfully challenged work restrictions that were unlawfully imposed on him based on perceived health limitations.

A federal appeals court upheld a lower court decision in favor of the foreman under the Americans with Disabilities Act (ADA). The foreman alleged that the railroad discriminated against him by imposing work limitations because of perceptions about his cardiovascular health and by failing to provide a reasonable accommodation during a related cardiovascular test. A jury had returned a verdict for the employee on both claims, awarding him damages in excess of $1 million.

The foreman’s position required him to oversee train mechanics, known as carmen, and to assume their responsibilities if none of them were available to respond to a distressed train. Some of the carmen’s responsibilities require significant physical exertion, including replacing “knuckles,” part of the equipment used to link the cars of a train together. These knuckles weigh approximately 86 pounds each.

The physical component of the foreman’s job became a problem only when he suffered complications related to a bleeding ulcer. One of those complications was a brief cardiac arrest. The employee was resuscitated, underwent a successful operation, and...

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