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MOTION INDUSTRIES3/15/1996
Motion Industries, Inc. ("Motion"), appeals a judgment based on a jury verdict in favor of Robert Theron Pate on his complaint alleging a retaliatory discharge. See § 25-5-11.1, Ala. Code 1975. The jury awarded $40,000 in compensatory damages and $210,000 in punitive damages. Motion argues for reversal on several grounds: that the trial court erred in submitting Pate's retaliatory discharge claim to the jury because, it argues, Pate did not prove that he was discharged, or, assuming that he was discharged, did not prove that his workers' compensation claim was the sole determining factor for the termination; that the jury's compensatory damages verdict was contrary to the great weight of the evidence; that the trial court erred in submitting the punitive damages claim; and that evidence regarding the Americans with Disabilities Act of 1990, 42 U.S.C. § 12101 et seq. ("ADA"), was erroneously admitted and misled the jury.
Both at the close of Pate's case and also at the close of all the evidence, Motion moved for a directed verdict. After the court entered a judgment on the jury verdict in favor of Pate, Motion moved for a judgment notwithstanding the verdict, or, in the alternative, for a new trial. The trial court denied both. After carefully considering the record, this Court affirms.
I. The Retaliatory Discharge Claim
Motion argues that Pate's claim of a retaliatory discharge is not supported by substantial evidence and that the trial court erred in denying its motions for a directed verdict and a judgment notwithstanding the verdict. In reviewing the denial of motions for directed verdict and J.N.O.V., this Court must apply the same standard the trial court applies to its rulings on the motions. Gold Kist, Inc. v. Griffin, 657 So.2d 826 (Ala. 1994); Continental Eagle Corp. v. Mokrzycki, 611 So.2d 313 (Ala. 1992). This Court determines whether the party with the burden of proof produced sufficient evidence to require a jury determination of the issue. Id. This Court must view the evidence in a light most favorable to the nonmoving party and must entertain such reasonable inferences as the jury would have been free to draw. Id.
Section 25-5-11.1 provides:
"No employee shall be terminated by an employer solely because the employee has instituted or maintained any action against the employer to recover workers' compensation benefits under this chapter or solely because the employee has filed a written notice of violation of a safety rule pursuant to subdivision (c)(4) of Section 25-5-11."
This section was enacted to offset the harsh effects of the employment-at-will doctrine. Morgan v. Northeast Alabama Regional Medical Ctr., 624 So.2d 560 (Ala. 1993). As remedial legislation, this section is construed liberally to effect its purposes. Twilley v. Daubert Coated Prods., Inc., 536 So.2d 1364 (Ala. 1988). For the beneficent goals of the workers' compensation chapter to be realized, the employee must be able to claim compensation for work-related injuries without being subject to reprisal. McClain v. Birmingham Coca-Cola Bottling Co., 578 So.2d 1299 (Ala. 1991).
An employee can establish a prima facie case of retaliatory discharge by proving that she or he was terminated for seeking workers' compensation benefits. That would be an impermissible reason for discharging an employee. The burden would then shift to the defendant employer to come forward with evidence that the employee was terminated for a legitimate reason; upon the employer's presentation of that evidence, the plaintiff would have to prove that the employer's reason was a pretext for an otherwise impermissible termination. Twilley v. Daubert Coated Prods., Inc., 53
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