Alexander v. Wmata, 82 F. Supp. 3d 388

Carlos Alexander, a former WMATA mechanic helper, was terminated in Jan 2009 after testing positive for alcohol; WMATA told him he could apply for rehire after completing an intensive treatment program.
Alexander completed inpatient alcohol treatment in Jan 2010 and applied for rehire multiple times (notified of denials in June 2010, Aug 2011, Oct 2011).
He filed an EEOC complaint in July 2010 and received a right-to-sue letter in Sept 2012; sued under the Rehabilitation Act in Dec 2012 (ADA claim voluntarily dismissed).
WMATA moved for summary judgment, arguing (1) the claims are time-barred and (2) Alexander is not a "qualified individual with a disability" because his alcoholism does not substantially limit a major life activity.
The court found the claims timely regardless of whether a one-year DCHRA period (with tolling during the administrative complaint) or a three-year period governed, but granted summary judgment because Alexander failed to show his alcoholism substantially limited any major life activity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness — which limitations period and tolling	Alexander argued his claim is timely (three-year period or one-year tolled during EEOC proceedings)	WMATA argued the one-year DCHRA period applies and claims are untimely; no tolling because administrative filing not required	Court assumed tolling under DCHRA or three-year period; found claims timely without deciding which period controls
Procedural exhaustion — required to toll	Alexander relied on EEOC filing to toll limitations	WMATA argued exhaustion not required so tolling inapplicable	Court applied DCHRA tolling regardless of whether exhaustion was required and proceeded to merits
Disability under Rehabilitation Act — whether alcoholism qualifies	Alexander claimed alcohol dependence substantially limits activities (sleeping, caring for self, concentrating, walking, working)	WMATA argued alcoholism not shown to substantially limit any major life activity; evidence is conclusory	Held for WMATA: Alexander failed to present nonconclusory evidence showing substantial limitation; summary judgment granted
Burden-shifting framework for discrimination claim	Alexander invoked Rehabilitation Act discrimination elements	WMATA stated even if prima facie established, Alexander did not prove disability element	Court applied McDonnell Douglas framework but resolved case on failure to prove disability element; did not reach other WMATA defenses

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (sets burden-shifting framework for discrimination claims)
Johnson v. Railway Express Agency, Inc., 421 U.S. 454 (1975) (discusses borrowing state statute of limitations and tolling principles)
Sutton v. United Air Lines, Inc., 527 U.S. 471 (1999) (establishes individualized inquiry for disability determination)
Haynes v. Williams, 392 F.3d 478 (D.C. Cir. 2004) (plaintiff must show substantial limitation, not just diagnosis)
Jaiyeola v. District of Columbia, 40 A.3d 356 (D.C. 2012) (construed to apply one-year DCHRA limitations to §504 claims)