Gianni-Paolo Ferrari v. Ford Motor Company
826 F.3d 885
| 6th Cir. | 2016Background
- Ferrari, a long‑term Ford employee, had a prior neck injury and long‑standing work restrictions; he took multiple medical/FMLA leaves and sought a skilled trades (RMI) apprenticeship in early 2013.
- Company physician Dr. Brewer retained two restrictions (no ladder‑climbing, no work at heights) after reviewing records, ordering new testing, and obtaining a binding independent medical exam that noted continued opioid use in records and cautioned against unrestricted work while on opioids.
- The RMI supervisors determined those ladder/height functions were essential and, under the collective bargaining agreement, temporarily bypassed Ferrari for the apprenticeship; Ford placed him in a restricted machining position instead.
- Ferrari sued under the ADA, Michigan’s PWDCRA, and for FMLA retaliation; the district court granted summary judgment for Ford and this appeal followed.
- The Sixth Circuit reviewed both the direct (regarded‑as) and indirect (McDonnell Douglas) theories for ADA claims and the indirect theory for FMLA retaliation, ultimately affirming summary judgment for Ford.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether opioid use was a "disability" under ADA (direct/regarded‑as) | Ferrari: Ford regarded his opioid use as disabling and thus unlawfully bypassed him | Ford: Employer only limited Ferrari from a single job/function (ladders/heights), not a broad class of jobs; thus not a substantial limitation on "working" | Held: No regarded‑as disability — inability to perform a single job is not a substantial limitation on working; direct claim fails |
| Whether Ferrari established a prima facie ADA discrimination case (indirect/McDonnell Douglas) | Ferrari: Neck injury/record of disability and restrictions made him qualified; bypass was adverse action | Ford: Restrictions (based on medical evaluation/opioid concerns) were a legitimate, non‑discriminatory reason for bypass | Held: Assuming prima facie case, Ford offered legitimate reason; Ferrari failed to raise a genuine dispute of pretext (honest belief in medical basis) |
| Whether Ford's asserted medical reason was pretextual | Ferrari: He had weaned off opioids; Dr. Kole cleared him; other evidence suggests bias or changed explanations | Ford: Decision followed binding independent exam, thorough review, and reasonable reliance on medical records indicating opioid use | Held: Ferrari failed to show pretext — Dr. Brewer and decision‑makers reasonably relied on the medical record and binding IME |
| FMLA retaliation — causal link and knowledge | Ferrari: Medical leaves (including psychiatric/FMLA leaves) prompted adverse action | Ford: No evidence Dr. Brewer or decision‑makers knew of FMLA use or that decision was causally connected to FMLA leave | Held: Ferrari failed to show decision‑makers knew of protected FMLA activity or any causal connection; FMLA claim fails |
Key Cases Cited
- Monette v. Elec. Data Sys. Corp., 90 F.3d 1173 (6th Cir. 1996) (sets out direct and indirect ADA frameworks and burdens)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (template for burden‑shifting in discrimination cases)
- Daugherty v. Sajar Plastics, Inc., 544 F.3d 696 (6th Cir. 2008) (clarifies "regarded‑as" standard: inability to perform a single job is not a substantial limitation on working)
- Whitfield v. Tennessee, 639 F.3d 253 (6th Cir. 2011) (reaffirmed Monette's five‑element prima facie ADA test and corrected prior misapplications)
- Smith v. Chrysler Corp., 155 F.3d 799 (6th Cir. 1998) (discusses the "honest belief" rule regarding employer's reliance on proffered reasons)