Phillip Cochran v. Eric Holder, Jr., 436 F. App'x 227

Cochran, a Deputy U.S. Marshal from 1986 to 1993, failed to meet the USMS hearing standard (whispered voice at 15 feet, without hearing aid).
In November 1992 Cochran learned he had sensorineural hearing loss, disqualifying him from service under the then-applicable standard.
Cochran retired for disability in April–June 1993 after the USMS recommended voluntary disability retirement due to risk in the work environment.
In 1994–1995 the USMS considered allowing hearing aids in testing and Cochran sought reinstatement, including a 1995 request after indicating recovery.
Cochran later filed RA discrimination claims alleging disability-based retirement and wrongful denial of reinstatement; the district court granted summary judgment for USMS.
On appeal, the Fourth Circuit reviews de novo the district court’s summary-judgment ruling and applies the RA/ADA framework to disability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Cochran disabled under the RA in 1993 for retirement claim?	Cochran argues impairment substantially limited a major life activity.	USMS contends impairment did not substantially limit hearing, not a disability.	No genuine disability at retirement; no substantial limitation.
Did Cochran have a record of disability or was he regarded as disabled?	Evidence showed prior concerns or recognition of impairment.	Records did not prove a substantial, long-term impairment or USMS perception of disability.	No record or regard found; not disabled under RA.
Was Cochran disabled in 1995 to support reinstatement claim?	Reinstatement sought due to recovered hearing without aids and/or changed policy.	Recovered hearing without aids means no impairment; reinstatement not required by disability status.	Not disabled in 1995; reinstatement claim fails.

Toyota Motor Mfg., Kentucky, Inc. v. Williams, 534 U.S. 184 (U.S. 2002) (substantially limits requires more than minor impairment)
Sutton v. United Air Lines, Inc., 527 U.S. 471 (U.S. 1999) (consider mitigation when determining disability)
Hooven-Lewis v. Caldera, 249 F.3d 259 (4th Cir. 2001) (RA/ADA disability formulations and standards)