Americans with Disabilities Act & PHRA Verdict
Corrections officer Darick Easterling served 19 years at the Delaware County Prison. After the county took direct control in 2022, it imposed mandatory back-to-back eight-hour shifts that conflicted with Easterling’s medically documented condition. When he requested an accommodation previously honored by the private operator, the county denied it and fired him.
Key Statutes
- Americans with Disabilities Act (ADA), 42 U.S.C. § 12112. Requires reasonable accommodation absent undue hardship.
- Pennsylvania Human Relations Act (PHRA), 43 P.S. § 955. Mirrors the ADA protections at the state level.
Litigation Highlights
- Failure-to-accommodate theory. The team showed the county could maintain staffing levels by modest schedule adjustments already in place.
- Two-phase federal trial. Liability was tried first; a Philadelphia jury found discrimination and ADA violation. The court then awarded just over $200,000 in back and front pay.
- No appeal. Facing a strong record, the county elected not to challenge the verdict.
Significance
The case underscores employers’ duty to honor existing accommodations during operational changes and confirms that schedule modifications are a classic form of reasonable accommodation.
Past results do not guarantee future outcomes. Every case is unique, and recoveries depend on specific facts and applicable law.
