Summary
This Eighth Circuit opinion addresses whether an employer "regarded" an employee as disabled under the Americans with Disabilities Act after restricting his work due to a perceived risk of future seizures following a traumatic brain injury. The court held that a genuine issue of material fact exists as to whether the medical examiner's report indicated a present impairment, thereby reversing the district court's grant of summary judgment. The case is remanded for further proceedings on the ADA claim and related issues such as qualification and direct threat defenses.
Topics
Practice areas
Questions Presented
- Whether Union Pacific ‘regarded’ Meza as disabled under the ADA for purposes of a discrimination claim
- Whether the district court’s grant of summary judgment was appropriate
Holdings
- The court holds that an employer’s belief that an employee may have a future impairment can satisfy the ‘regarded‑as disabled’ prong of the ADA, creating a genuine issue of material fact.
- The court vacates the district court’s summary‑judgment grant and remands for further proceedings because genuine issues of material fact exist.
Key quotations
“What does it take for an employer to “regard[]” an employee as disabled under the Americans with Disabilities Act? 42 U.S.C. § 12102(1)(C).” (at 2)
“We are not ruling out the possibility that the district court could grant summary judgment on another ground it “did not reach.” United Fire & Cas. Co. v. Titan Contractors Serv., Inc., 751 F.3d at 887.” (at 5)
Factual background
Meza, a long‑time Union Pacific employee, suffered a non‑job‑related motorcycle accident resulting in a brain hemorrhage. Although treating physicians initially said he had fully recovered, Union Pacific’s medical examiner feared future seizures and restricted Meza’s work for five years, leading to his suspension.
Procedural history
The district court concluded Union Pacific had not ‘regarded’ Meza as disabled and granted summary judgment in favor of Union Pacific. Meza appealed.
Remand instructions
Further proceedings on the ADA ‘regarded‑as’ claim, including determination of Meza’s qualification for his position and whether his condition poses a direct threat under 42 U.S.C. § 12113(b).