The full case caption appears at the end of this opinion.
Randall Webner sued his employer, Titan Distribution, Inc. (Titan), alleging that Titan had discriminated against him in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. �� 12101-12213 (1994 & Supp. IV 1998), and also asserted a state law claim that Titan retaliated against him by terminating his employment after he filed a workers’ compensation claim. The jury agreed as to both claims, returning a verdict in Webner’s favor and awarding him compensatory and punitive damages. After the district court entered judgment on the verdict, Titan moved for judgment as a matter of law or, alternatively, a new trial, which the district2 court denied. We affirm the jury’s liability finding on both the ADA claim and the supplemental state law retaliation claim, affirm the award of emotional distress damages, but reverse the jury’s award of punitive damages.
I.
The record, when viewed in the light most favorable to Webner, shows the following facts. Webner began his association with Titan in 1991 while he was employed by Titan’s predecessor, Neiman’s, in Ventura, Iowa. Neiman’s was a family-owned business specializing in brake and actuator assemblies that were mounted onto trailers. Neiman’s primary customer was Titan, which ultimately purchased the Ventura facility in 1996. Webner’s first job at Neiman’s was as a truck driver charged with delivering axles, tires, and brake parts. In 1994, Webner suffered a work-related herniated disk in his back while unloading tires from his truck. Webner had surgery and was off work recovering for six months. Three months after returning to work in 1995, he suffered another work-related back injury while driving a truck with a broken seat. Doctors diagnosed Webner with a new herniated disk in his back. Webner underwent a second back surgery in March 1996 where doctors inserted a metal plate into his back. The second surgery left Webner with severe pain in his left leg and numbness in his foot. In July 1996, doctors removed the plate from Webner’s back in hopes of ameliorating his pain and numbness. After extensive rehabilitation, Webner was able to return to work full time at Titan in January 1997–a year and a half after his second injury. Because Webner’s former truck driving position had been eliminated when Titan purchased the Neiman’s facility, Titan assigned Webner to the assembly line. Webner’s physician imposed several work restrictions upon his return, including a lifting restriction that allowed him to lift up to 50 pounds on occasion, up to 35 pounds more frequently, and 15 to 25 pounds continuously. Webner was also restricted from twisting and bending no more than 12 times per hour.
