Gavin Class v. Towson University, 806 F.3d 236

Background

In Aug. 2013 Gavin Class, a Towson University student and football player, suffered near-fatal exertional heatstroke requiring a liver transplant and prolonged hospitalization; he later sought to return to Division I football.
Towson’s written Return-to-Play Policy gives the Team Physician final authority to clear injured student‑athletes; Dr. Kari Kindschi (Towson’s Team Physician) reviewed Class’s history and multiple Korey Stringer Institute heat‑tolerance tests and denied full clearance, allowing only no‑contact conditioning in a cool environment.
Class proposed accommodations (abdominal padding, internal temperature monitoring via a CorTemp ingestible sensor, adherence to acclimatization guidelines, fluid monitoring, and medical supervision) and sued under Title II of the ADA and §504 of the Rehabilitation Act after Towson refused to fully reinstate him.
The district court found Class disabled under the ADA/Rehabilitation Act and enjoined Towson, concluding the proposed accommodations were reasonable; Towson appealed.
The Fourth Circuit reversed: it assumed the disability question was close but held Class was not “otherwise qualified” because Towson reasonably applied its Return‑to‑Play Policy and the Team Physician’s individualized medical judgment was supported by evidence and entitled to deference.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Class is a "disabled" person under the ADA	Class: heatstroke history and impaired thermoregulation substantially limit major life activities (or constitute a record of impairment)	Towson: increased risk is just a risk and activation occurs only under extreme athletic conditions, not a major life activity	Court: closeness acknowledged; did not decide; resolved case on qualification ground
Whether Class was "otherwise qualified" for football with accommodations	Class: proposed accommodations (padding, CorTemp monitoring, supervision) would allow safe participation	Towson: accommodations would not eliminate catastrophic risk, impose burdens, and would fundamentally alter program and physician’s role	Court: Towson’s Team Physician reasonably rejected accommodations; Class not otherwise qualified; judgment reversed
Standard/deference for school medical eligibility decisions	Class: district court should weigh competing experts and could find accommodations reasonable	Towson: Team Physician’s individualized medical judgment deserves deference	Court: apply deference—decision must be individualized, reasonably made, and based on competent medical evidence; substantial evidence supported Towson
Reasonableness of specific accommodations (CorTemp monitoring; medical supervision)	Class: CorTemp monitoring and medical oversight can prevent dangerous overheating and are feasible	Towson: monitoring unreliable in practice (sensor variability, logistics during games), cannot guarantee prevention, and direct‑observation requirement would alter program/physician role	Court: monitoring/logistical limitations and residual risk supported Team Physician’s rejection; accommodation unreasonable or would fundamentally alter program

Key Cases Cited

Toyota Motor Mfg., Ky., Inc. v. Williams, 534 U.S. 184 (2002) (pre‑ADAAA standard for ‘‘substantially limits’’ analyzed)
Halpern v. Wake Forest Univ. Health Sciences, 669 F.3d 454 (4th Cir. 2012) (deference to schools’ professional judgments on qualifications)
Davis v. Univ. of N.C., 263 F.3d 95 (4th Cir. 2001) (courts ill‑equipped to evaluate medical judgments for academic/clinical qualifications)
Knapp v. Northwestern Univ., 101 F.3d 473 (7th Cir. 1996) (university medical determinations must be individualized, reasonable, and based on competent medical evidence)
Doe v. Univ. of Md. Med. Sys. Corp., 50 F.3d 1261 (4th Cir. 1995) (significant risk to health/safety can make a person not otherwise qualified)
Southeastern Cmty. Coll. v. Davis, 442 U.S. 397 (1979) (technical standards and essential eligibility requirements)
Chevron U.S.A. Inc. v. Echazabal, 536 U.S. 73 (2002) (employer may consider disability risk to employee when assessing qualification)
Sch. Bd. of Nassau Cnty. v. Arline, 480 U.S. 273 (1987) (use reasonable medical judgments to assess risk and duration/severity/probability of harm)
Bragdon v. Abbott, 524 U.S. 624 (1998) (assess objective reasonableness of health‑care professionals’ risk assessments without deferring to subjective views)
PGA Tour, Inc. v. Martin, 532 U.S. 661 (2001) (fundamental‑alteration analysis for accommodations)
Bd. of Curators of the Univ. of Mo. v. Horowitz, 435 U.S. 78 (1978) (deference to school judgments in academic/professional qualifications)