Brian Wurzel v. Whirlpool Corporation, 482 F. App'x 1

Wurzel, a Whirlpool materials handler at Clyde Division, primarily operated a tow motor in a safety-sensitive plant with moving machinery and pedestrian traffic.
Wurzel suffers Prinzmetal angina with unpredictable chest-pain spasms and requires nitroglycerin; dizziness and fatigue can accompany episodes.
Whirlpool’s plant physician (Dr. Marshall) initially returned Wurzel-to-work without restrictions but later imposed restrictions due to concerns about sudden incapacitation.
An independent medical examiner (Dr. Biswas) evaluated Wurzel and recommended restrictions; Whirlpool also considered treating cardiologists’ opinions.
From 2008 to 2009, Wurzel experienced multiple spasms at work; stakeholders debated whether he could return to work safely, particularly around machinery and heights.
Whirlpool ultimately determined Wurzel could not safely perform the essential functions of his paint-department position under restrictions and he went on sick leave; in 2010 he returned to work in a restricted/alternative role, but. The district court granted Whirlpool summary judgment on the ADA claims; the Sixth Circuit affirmed, focusing on direct-threat legality and qualified status under ADA/ADAAA.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Whirlpool’s direct-threat finding was reasonably based.	Wurzel contends Marshall discounted treating physicians and relied on incomplete information.	Whirlpool asserts Marshall had current information, reviewed records, consulted Issa/Stockton, and obtained Biswas’s IME.	Yes; the court held the direct-threat finding was reasonably based on medical judgment and individualized assessment.
Whether Wurzel was “otherwise qualified” given the direct threat.	Wurzel argues he was qualified with accommodations; the threat determination should not bar qualification.	Whirlpool asserts direct threat precludes qualification as a defense to liability.	No; the court held he was not qualified due to posing a direct threat.
Whether the ADAAA or pre-ADA amendments govern and affect the outcome.	Argues under either version, the evidence supports a disability/regarded-as status.	Acknowledges timing but maintains outcome is governed by direct-threat analysis, not mere disability status.	Courts’ outcome is resolved on direct-threat analysis; the result stands under either version.
Which party bears the burden to prove direct threat and how.	Plays role in burden-shifting; plaintiff contends burden that supports lack of threat.	Employer bears or the issue is properly analyzed as a defense; the record supports director threat.	The court treated the direct-threat determination as supported by the record and affirmed on that basis.

Estate of Mauro v. Borgess Med. Ctr., 137 F.3d 398 (6th Cir. 2000) (direct-threat analysis with four factors; individualized medical evidence required)
Holiday v. City of Chattanooga, 206 F.3d 637 (6th Cir. 2000) (direct-threat framework; need for factual risk assessment)
Mauro, 137 F.3d 398, 137 F.3d 398 (6th Cir. 2000) (same direct-threat framework (see Mauro))
Bragdon v. Abbott, 524 U.S. 624 (1998) (medical evidence/standard for direct-threat judgments)
Moses v. American Nonwovens, Inc., 97 F.3d 446 (11th Cir. 1996) (epileptic worker direct-threat near dangerous machinery)
Hutton v. Elf Atochem North America, Inc., 273 F.3d 884 (9th Cir. 2001) (diabetic hypoglycemic risk on equipment; direct-threat analysis)