City of Houston v. Shayn A. Proler, 437 S.W.3d 529

Shayn Proler, a Houston firefighter and captain, was reassigned after a 2004 incident where a coworker alleged he wouldn’t enter a burning building.
In March 2006, Proler could not don firefighting gear, had trouble walking, and appeared disoriented at a house fire, leading to reassignment and medical evaluation.
Proler filed an administrative grievance under a collective bargaining agreement seeking reassignment; a hearing examiner granted reassignment to fire suppression, later reversed on appeal, with further litigation in trial court.
The trial court awarded Proler injunctive relief and substantial attorney’s fees after a disability discrimination verdict under ADA and Texas Labor Code Chapter 21.
The court of appeals reversed some rulings but affirmed other disability-discrimination relief; the Texas Supreme Court granted review to address whether Proler had a disability or was perceived to have one.
The Court held that Proler did not prove disability or being regarded as disabled, reversed the take-nothing judgment on disability claims, and remanded for other issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Proler have a disability under ADA/Texas law?	Proler was disabled or perceived as disabled due to depression.	There was no evidence of a disability or perceived disability.	No disability established; no substantial limitation shown.
Was Proler regarded as disabled by the City?	Evidence showed perception of impairment affected job status.	No evidence City perceived a mental impairment affecting major life activities.	Not established; no perception of impairment supported.
Did the City’s reassignments constitute disability discrimination?	Reassignments were motivated by disability/perception thereof.	Reassignments were based on specific job performance and safety concerns, not disability.	Discrimination claim cannot be sustained; record shows job-performance-based actions.

Toyota Motor Corp. v. Williams, 534 S. Ct. 184 (2002) (inability to perform a broad range of work-related tasks)
Sutton v. United Airlines, Inc., 527 U.S. 471 (1999) (major life activity not substantially limited by inability to perform a single job)
City of Keller v. Wilson, 168 S.W.3d 802 (Tex. 2005) (standard for appellate review of legal sufficiency in Texas)
Haggar Apparel Co. v. Leal, 154 S.W.3d 98 (Tex. 2004) (definition of disability under Texas Labor Code aligned with ADA)
Thomann v. Lakes Reg’l MHMR Ctr., 162 S.W.3d 788 (Tex. App.—Dallas 2005) (qualification for other positions indicates not per se disability)
Waffle House, Inc. v. Williams, 313 S.W.3d 796 (Tex. 2010) (consolidates federal and state disability standards in Texas)