Quinton Harris v. Union Pacific Railroad Company, 953 F.3d 1030

Union Pacific’s Health and Medical Services (HMS) evaluates employees after certain "reportable health events" (e.g., heart attack, stroke, seizure); employees are removed from duty during evaluation.
HMS applies medical guidelines and may impose "functional work restrictions" based on an acceptable risk threshold (no greater than 1% annual risk of sudden incapacitation); supervisors then assess whether employees can perform essential job functions with or without accommodation.
Quinton Harris and other current/former employees sued under the ADA (42 U.S.C. § 12112(a), (b)(6)), alleging the fitness-for-duty policy systematically removes workers with disabilities.
The district court certified a hybrid Rule 23(b)(2) (injunctive/declaratory relief) and Rule 23(b)(3) (damages) class comprising employees subject to fitness-for-duty evaluations since Sept. 18, 2014, and adopted a two-stage (Teamsters-style) trial plan.
Union Pacific appealed, arguing certification was improper because individualized, job-specific inquiries (job-relatedness and business necessity) defeat Rule 23(b)(2) cohesion and Rule 23(b)(3) predominance/superiority.
The Eighth Circuit assumed (without deciding) the Teamsters framework might apply to ADA pattern-or-practice claims but held the district court abused its discretion in certifying the class because individualized inquiries would overwhelm any common proof.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 23(b)(2) (cohesiveness) permits class certification	Policy is facially discriminatory and a classwide injunction can provide relief	Determination requires individualized, job-by-job and condition-by-condition analysis (job-relatedness/business necessity)	Reversed: class fails 23(b)(2) cohesiveness because resolution requires individualized inquiries
Whether Rule 23(b)(3) (predominance/superiority) permits class certification	A common predominant question exists (policy unlawfully discriminatory) and the same evidence can prove classwide liability	Individual questions (over 650 distinct positions, different conditions) predominate; district court did not perform a rigorous predominance analysis	Reversed: predominance not met; district court abused discretion; superiority not decided conclusively
Whether the Teamsters two-stage framework can cure individualized ADA inquiries	Teamsters-style pattern-or-practice proof allows class treatment of discrimination claims	Teamsters cannot avoid ADA requirements that job-relatedness and business necessity be assessed per position/condition	Court assumed Teamsters could apply but concluded it cannot cure the fundamental individualized nature of the ADA inquiry; certification improper

Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338 (2011) (Rule 23(b)(2)/(b)(3) certification requires classwide questions that can generate common answers)
Int’l Bhd. of Teamsters v. United States, 431 U.S. 324 (1977) (two-step framework for pattern-or-practice discrimination proof)
Hohider v. United Parcel Serv., Inc., 574 F.3d 169 (3d Cir. 2009) (applying Teamsters framework to ADA claims and emphasizing need to examine ADA elements for class treatment)
Ebert v. Gen. Mills, Inc., 823 F.3d 472 (8th Cir. 2016) (predominance requires rigorous analysis of common vs. individual questions)
Avritt v. Reliastar Life Ins. Co., 615 F.3d 1023 (8th Cir. 2010) (23(b)(2) inappropriate when conduct requires individualized evaluation)
Belk v. Sw. Bell Tel. Co., 194 F.3d 946 (8th Cir. 1999) (employer asserting business necessity must validate test/job-relatedness for specific position)
Bates v. United Parcel Serv., Inc., 511 F.3d 974 (9th Cir. 2007) (job-relatedness requires demonstration that standard fairly measures ability to perform essential functions)
Postawko v. Mo. Dep’t of Corr., 910 F.3d 1030 (8th Cir. 2018) (appellate review requires district courts to perform rigorous predominance analysis)