General Dynamics Information Technology Ltd v Carranza (Disability Discrimination : Reasonable adjustments) [2014] UKEAT 0107_14_1009 (10 September 2014)

General Dynamics Information Technology Ltd v Carranza (Disability Discrimination : Reasonable adjustments) [2014] UKEAT 0107_14_1009 (10 September 2014)

The Employment Tribunal erred in law by failing to identify a practical 'step' for reasonable adjustment and by requiring the employer to review or disregard the final written warning without legal basis. The duty to make reasonable adjustments was not breached, and the dismissal was not unfair as the employer was entitled to rely on the final written warning issued in good faith.

Citation
[2014] UKEAT 0107_14_1009
Parties
Appellant: General Dynamics Information Technology Ltd; Respondent: Mr Andy Carranza
Jurisdiction
United Kingdom
Judgment Date
10 September 2014
Procedural Posture
Employment Appeal Tribunal / Appeal From Employment Tribunal Judgment
Outcome
Appeal allowed; findings of disability discrimination and unfair dismissal set aside.
Legal Topics
Disability Discrimination, Reasonable Adjustments, Unfair Dismissal
Employment Law Equality Law Disability Discrimination Reasonable Adjustments Unfair Dismissal

Case Brief

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Parties

General Dynamics Information Technology Ltd

Appellant

Mr Andy Carranza

Respondent

Procedural Posture

Employment Appeal Tribunal / Appeal From Employment Tribunal Judgment

Legal Issues

  1. 1 Whether failure to disregard disability-related sickness absence amounted to breach of duty to make reasonable adjustments under Equality Act 2010
  2. 2 Whether dismissal was unfair due to procedural defects in reviewing final written warning

Ratio Decidendi

The Employment Tribunal erred in law by failing to identify a practical 'step' for reasonable adjustment and by requiring the employer to review or disregard the final written warning without legal basis. The duty to make reasonable adjustments was not breached, and the dismissal was not unfair as the employer was entitled to rely on the final written warning issued in good faith.

Court Disposition

Appeal allowed; findings of disability discrimination and unfair dismissal set aside.

Orders

  • Claims of disability discrimination and unfair dismissal dismissed.