Griffin v. United Parcel Service, Inc., 661 F.3d 216

Griffin, an insulin-dependent Type-II diabetic, worked for UPS for nearly 28 years, most recently as twilight hub manager; his shift ran 2:00 pm–10:00 pm five days weekly.
Griffin requested a daytime schedule accommodation to manage his diabetes after returning from medical leave in June 2006.
UPS assigned Griffin to a midnight hub manager position, which would have conflicted with his request for daytime hours.
Griffin provided medical documentation supporting daytime work but UPS requested additional forms and information.
After UPS denied the accommodation in November 2006, Griffin retired in December 2006 and filed a charge with the EEOC in 2007; district court granted UPS summary judgment in 2010.
Griffin appeals, arguing disability under the ADA and failure to provide a reasonable accommodation; the appellate court affirms both the disability determination and the accommodation ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Griffin is disabled under the ADA.	Griffin's diabetes substantially limits eating, a major life activity.	Griffin's restrictions are modest and do not substantially limit eating.	Griffin not disabled under the ADA.
Whether UPS failed to provide a reasonable accommodation.	UPS did not engage in a good-faith interactive process and should have accommodated daytime hours.	No evidence of an required accommodation; Griffin did not show available alternative positions or necessary information; he retired before further discussion.	No genuine issue; UPS properly accommodated via interactive process and denial was reasonable.

Sutton v. United Air Lines, Inc., 527 U.S. 471 (U.S. 1999) (individualized disability inquiry; avoid per se disability for diabetes)
Waldrip v. General Electric Co., 325 F.3d 652 (5th Cir. 2003) (ADA disability threshold requires substantial limitation by actual impairment)
Toyota Motor Mfg. v. Williams, 534 U.S. 184 (U.S. 2002) (individualized inquiry for diabetes, symptoms vary per person)
Jenkins v. Cleco Power, LLC, 487 F.3d 309 (5th Cir. 2007) (discrimination requires disability, qualification, and failure to accommodate)
Loulseged v. Akzo Nobel Inc., 178 F.3d 731 (5th Cir. 1999) (withdrawal from interactive process affects reasonableness)
Agro Distrib., Inc. v. E.E.O.C., 555 F.3d 462 (5th Cir. 2009) (interactive process; burden on employee when information is deficient)
Carreras v. Sajo, Garcia & Partners, 596 F.3d 25 (1st Cir. 2010) (diabetes dietary restrictions; not necessarily a substantial limitation)
Fraser v. Goodale, 342 F.3d 1032 (9th Cir. 2003) (dietary restrictions; nuance in disability determination)
Collado v. United Parcel Serv., Co., 419 F.3d 1143 (11th Cir. 2005) (dietary monitoring not per se disabling)