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The Eighth Circuit affirmed summary judgment for Union Pacific, holding that judicial estoppel barred Cook's ADA discrimination claim because his positions in the FELA proceeding (that he was permanently disabled and unfit to work) were materially inconsistent with his later ADA claim that he could perform locomotive engineer duties.
Cook v. Union Pacific Railroad: Worker's Inconsistent Claims Lead to Case Dismissal
Rodney Cook, a railroad employee, filed two separate legal claims against Union Pacific Railroad after suffering a workplace injury. First, he filed a Federal Employers' Liability Act (FELA) claim, arguing he was permanently disabled and unable to work. Later, he filed an Americans with Disabilities Act (ADA) discrimination lawsuit, claiming the company failed to accommodate his disability and that he could actually perform his job as a locomotive engineer with reasonable accommodations.
The court ruled against Cook, dismissing his ADA case entirely. The judge found that Cook couldn't argue he was completely unable to work in one lawsuit, then turn around and claim he could work with accommodations in another lawsuit. This legal principle, called "judicial estoppel," prevents people from taking contradictory positions in different court cases.
This ruling matters for workers because it shows the importance of consistency when filing multiple legal claims. If you're injured at work and considering legal action, you need to carefully think through your position before filing different types of lawsuits. Contradictory arguments in separate cases can result in losing both claims entirely, even if you might have had a valid case under one law or the other.
This summary was generated to explain the ruling in plain English and is not legal advice.
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