Richard Samson v. Federal Express Corporation
746 F.3d 1196
| 11th Cir. | 2014Background
- Samson, a Type-1 insulin-dependent diabetic, applied for a FedEx Technician position contingent on a DOT medical exam and Florida CDL requirements.
- Samson failed the DOT exam due to diabetes, and FedEx withdrew the job offer, asserting FMCSRs compelled the decision.
- FedEx argued the Technician role might involve test-driving trucks, which could trigger DOT certification and license prerequisites.
- Samson alleged FedEx used a discriminatory qualification standard by conditioning employment on DOT certification for a non-driving mechanic position.
- The district court granted summary judgment to FedEx on both ADA/FCRA discrimination and FMCSRs defenses, which the Eleventh Circuit reversed and remanded.
- On remand, the question became whether test-driving is an essential function and whether FMCSRs provide a defense, given intrastate vs interstate commerce distinctions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is test-driving an essential function of the Technician role? | Samson argues test-driving is essential, thus he could be qualified with accommodation. | FedEx contends test-driving is essential and required by the job and safety concerns. | Genuine factual dispute exists; not exclusively essential. |
| Do FMCSRs provide a complete defense to disability claims? | FMCSRs do not automatically justify a blanket defense for a non-driving mechanic. | FMCSRs require DOT certification for positions involving interstate commerce. | FMCSRs do not obligate FedEx to require certification for Samson; intrastate test-driving matters. |
| Does test-driving within the Fort Myers area constitute interstate commerce driving? | Test-driving could involve interstate commerce depending on operations; not limited to intrastate. | Test-driving of empty trucks locally is intrastate, not interstate. | Occasional local test-driving not interstate commerce; FMCSRs not a defense but do not override discrimination claim. |
| Should the district court have resolved the issue of FMCSRs applicability at summary judgment? | There were genuine disputes about the function's essential nature and FMCSRs applicability. | FMCSRs clearly apply only if test-driving involves interstate commerce. | Reversal and remand to address summary judgment on Samson’s discrimination claim. |
Key Cases Cited
- Holly v. Clairson Indus., LLC, 492 F.3d 1247 (11th Cir. 2007) (essential functions framework; weight of employer’s judgment; business necessity)
- D’Angelo v. ConAgra Foods, Inc., 422 F.3d 1220 (11th Cir. 2005) (case-by-case evaluation of essential functions and job descriptions)
- Keith v. Cnty. of Oakland, 703 F.3d 918 (6th Cir. 2013) (case discussing factors for essential functions and job analysis)