Troy K. Scheffler v. Ramona Dohman

Summary

Troy K. Scheffler challenged Minnesota’s restrictions and cancellation of his driving privileges under the Americans with Disabilities Act, asserting that the State regarded him as alcoholic or that his DWI convictions created a record of alcoholism. The Eighth Circuit held that the complaint did not allege facts establishing an ADA disability under any of the statute’s three definitions. The court affirmed dismissal under Federal Rule of Civil Procedure 12(b)(6).

Holdings

1. Scheffler did not allege that he was an alcoholic or that alcoholism substantially limited a major life activity, and therefore he failed to plead a disability under the ADA's first definition.
2. Multiple DWI convictions, without more, do not establish that a person is an alcoholic or that the person has a record of an impairment substantially limiting a major life activity.
3. The State's imposition of restrictions on a driver with multiple DWI offenses did not, without additional facts, establish that the State regarded Scheffler as having an alcoholism-related impairment.
4. The district court properly dismissed the complaint for failure to state a claim because Scheffler failed to allege that he was disabled under the ADA.

Questions Presented

1. Whether Scheffler adequately alleged that he had an ADA disability based on an actual alcoholism-related impairment that substantially limited a major life activity.
2. Whether multiple DWI convictions and related state-imposed driving restrictions established a record of alcoholism under the ADA.
3. Whether the State regarded Scheffler as having an alcoholism-related impairment under the ADA.

Disposition

affirmed