Ninth Circuit Rules No Compensatory/Punitive Damages, No Jury Trial in ADA Retaliation Claims


On December 11, 2009, the Ninth Circuit Court of Appeals ruled in Alvarado v. Cajun Operating Company that Americans with Disabilities Act retaliation claims are limited to “equitable relief,” including injunctive relief and backpay.

In the decision below, the United States District Court for the District of Arizona granted Cajun summary judgment on Alvarado’s ADA discrimination claim, but denied summary judgment on Alvarado’s retaliation claim, as well as his age discrimination claim.

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