REBECCA EDWARDS, v. SHELBY COUNTY, TENNESSEE, a Tennessee municipality operating as the Shelby County Health Department - Articles

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REBECCA EDWARDS, v. SHELBY COUNTY, TENNESSEE, a Tennessee municipality operating as the Shelby County Health Department

Posted by: Azya Thornton on Nov 10, 2025

Head Comment: CORRECTION: This opinion mistakenly ran under the Tennessee Court of Appeals category on Nov. 7, 2025

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ARGUED: E. Lee Whitwell, SHELBY COUNTY, Memphis, Tennessee, for Appellant.

Attorneys 2: ARGUED: Steven G. Wilson, THE STEVE WILSON FIRM, Memphis, Tennessee, for Appellee.

Attorneys 3: ON BRIEF: E. Lee Whitwell, R.H. “Chip” Chockley, Julia Marie Hale, SHELBY COUNTY, Memphis, Tennessee, for Appellant.

Attorneys 4: ON BRIEF: Steven G. Wilson, THE STEVE WILSON FIRM, Memphis, Tennessee, Matthew C. Gulotta, THE GULOTTA FIRM, PLLC, Memphis, Tennessee, for Appellee.

Judge(s): MOORE, BUSH, and NALBANDIAN, Circuit Judges

Court Appealed: United States District Court for the Western District of Tennessee at Memphis

JOHN K. BUSH, Circuit Judge. Rebecca Edwards, a former Shelby County Health Department employee, brought this action under the Americans with Disabilities Act (ADA), asserting three claims. She alleges that the County (1) discriminated against her based on her night blindness, (2) retaliated against her for requesting a related accommodation, and (3) failed to accommodate a separate condition (her asthma). Following a two-day trial, the jury returned a verdict in her favor on all three claims. The County now appeals, contending that Edwards is not disabled under the ADA and that the evidence did not support the jury’s verdict. The County primarily argues that neither Edwards’s night blindness nor her asthma qualifies as a disability under the ADA, especially given her admitted ability to drive at night on some occasions. But while the evidentiary record is limited, it is not legally insufficient. Edwards testified in detail about the effect of her impairments on her daily functioning, and the jury was entitled to credit that testimony. And under the ADA’s fact-driven, individualized inquiry, the jury’s determination that Edwards is disabled was not unreasonable. So the County’s argument falls short of the standard required to disturb a jury verdict. We AFFIRM the district court’s entry of judgment on Edwards’s disability-discrimination, retaliation, and failure-to-accommodate claims.

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