Alexander v. Washington Metropolitan Area Transit Authority
423 U.S. App. D.C. 380
| D.C. Cir. | 2016Background
- Carlos Alexander was employed by WMATA, had long-standing alcoholism, was suspended in 2007 after a positive breathalyzer, returned under an EAP, then in 2009 was terminated after another positive test.
- WMATA told Alexander he could reapply after completing an intensive treatment program; he completed such a program in January 2010 and sought rehire multiple times in 2010–2011 but was repeatedly disqualified.
- Alexander filed an EEOC charge in September 2010 alleging ADA discrimination; EEOC found reasonable cause and issued a right-to-sue letter in 2012. He sued under the Rehabilitation Act (later dismissing the ADA claim).
- The district court granted summary judgment to WMATA, finding Alexander failed to show an actual disability that substantially limited a major life activity.
- The D.C. Circuit reversed, holding the district court erred by failing to consider the Rehabilitation Act’s three alternative definitions of “disability” (actual impairment, record of, and regarded as) and by applying pre-2008, stricter standards for “substantially limits.”
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Alexander is a "disabled" individual under the Rehabilitation Act | Alexander argued he is disabled: (1) actual impairment (alcoholism substantially limits major life activities), (2) record of impairment, and (3) WMATA regarded him as impaired | WMATA argued Alexander failed to show his alcoholism substantially limited major life activities (and thus no disability) and asserted non-discriminatory grounds for non-hire | Reversed: a reasonable jury could find Alexander qualifies under all three prongs; district court erred by not evaluating record-of and regarded-as prongs and by applying an overly demanding substantially-limits test |
| Whether a regarded-as claim requires showing substantial limitation | Alexander argued regarded-as does not require showing substantial limitation post-ADA Amendments | WMATA implicitly relied on pre-Amendment substantial-limitation focus | Held: post-2008 Amendments regarded-as claims do not require a showing that the impairment limits a major life activity; only discriminatory action because of actual or perceived impairment is required |
| Sufficiency of evidence that WMATA refused to rehire because of disability | Alexander pointed to statements by WMATA personnel, shifting explanations for disqualification, evidence he completed treatment, and EEOC findings | WMATA claimed falsified medical form and lack of required documentation justified non-hire | Held: triable issues exist—testimony and records permit a reasonable jury to infer discriminatory motive and cast doubt on WMATA’s proffered reasons |
| Timeliness / statute of limitations | Alexander argued his suit was timely; EEOC filing tolled limitations under D.C. law or three-year personal-injury period applies | WMATA argued Rehabilitation Act claim is time-barred under D.C. Human Rights Act one-year limit | Held: claim timely either way — three-year period would obviously cover it, and if one-year HRA applies, tolling via EEOC filing (per D.C. law and worksharing) makes filing timely |
Key Cases Cited
- Solomon v. Vilsack, 763 F.3d 1 (D.C. Cir.) (summary-judgment standard review)
- Bailey v. Georgia-Pacific Corp., 306 F.3d 1162 (1st Cir.) (alcoholism qualifies as an impairment under ADA)
- Johnson v. Railway Express Agency, Inc., 421 U.S. 454 (1975) (tolling and interplay of limitations periods across statutes)
- Dandridge v. Williams, 397 U.S. 471 (1970) (appellee may assert alternative grounds on appeal)
- Hardin v. Straub, 490 U.S. 536 (1989) (courts should not unravel state limitations rules when borrowing them)