Daryle McNelis v. Pennsylvania Power & Light Co, 867 F.3d 411

McNelis was hired in 2009 as an armed Nuclear Security Officer with unrestricted access and authority to use deadly force at PPL’s nuclear plant.
In April 2012 he exhibited paranoid behavior, possible substance abuse, was hospitalized briefly for psychiatric care, and coworkers reported safety concerns.
NRC regulations require nuclear security personnel to pass fitness-for-duty evaluations and maintain unescorted access authorization (including psychological assessment and ongoing behavioral observation).
A third‑party psychologist, Dr. Thompson, concluded McNelis was not fit for duty pending further alcohol assessment; PPL revoked his unescorted access and terminated his employment.
McNelis sued under the ADA (and related statutes) claiming he was wrongly regarded as disabled; the District Court granted summary judgment for PPL. The Third Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether McNelis was a "qualified individual" under the ADA	McNelis was erroneously regarded as disabled but still entitled to ADA protection	McNelis lacked required, legally‑mandated fitness and unescorted access, so he could not perform essential job functions	McNelis was not a qualified individual; summary judgment for PPL affirmed
Whether PPL denied McNelis adequate process or opportunity to address the fitness determination	McNelis should have been given more opportunity to challenge/restore access before termination	NRC regulations supplied specific review procedures and PPL was obliged to follow them	NRC procedures were sufficient; PPL properly followed them
Whether PPL could rely on Dr. Thompson’s fitness determination despite contrary evidence	McNelis proffered physicians who reached different conclusions; a jury could find Dr. Thompson wrong	Courts should not second‑guess regulatory medical determinations; NRC bars a second determination once performed by a qualified professional	PPL was entitled to rely on the determination; courts should not reweigh it
Whether compliance with federal safety regulations limits ADA relief	McNelis argued ADA protections should apply fully even in safety‑sensitive roles	Federal safety regulations (NRC) impose binding job qualifications that can limit ADA claims	Federal safety rules control; employers may insist on compliance, which can be a defense to ADA claims

Albertson's, Inc. v. Kirkingburg, 527 U.S. 555 (U.S. 1999) (employer may insist on compliance with binding federal safety qualifications limiting ADA relief)
Murphy v. United Parcel Serv., Inc., 527 U.S. 516 (U.S. 1999) (courts should not second‑guess regulatory medical determinations in ADA context)
Hawkins v. Schwan's Home Serv., Inc., 778 F.3d 877 (10th Cir. 2015) (failure to meet DOT medical standards means not qualified under ADA)
Gaul v. Lucent Techs., Inc., 134 F.3d 576 (3d Cir. 1998) (two‑part test for "qualified individual": prerequisites and ability to perform essential functions)
Brickers v. Cleveland Bd. of Educ., 145 F.3d 846 (6th Cir. 1998) (legally defined job qualifications are by nature essential functions)
Blunt v. Lower Merion Sch. Dist., 767 F.3d 247 (3d Cir. 2014) (standard of plenary review on summary judgment issues cited for procedural posture)