Sakari Jarvela v. Crete Carrier Corporation, 754 F.3d 1283

Jarvela, a commercial truck driver, was diagnosed with alcoholism by his physician in March 2010 and took FMLA leave for treatment; he completed an outpatient program and sought to return in April 2010.
Crete Carrier terminated Jarvela after its safety VP concluded he had a "current clinical diagnosis of alcoholism," citing DOT regulations and Crete’s five-year company policy barring recent alcoholism diagnoses.
Jarvela sued under the ADA (disability discrimination / failure to accommodate) and the FMLA (interference and retaliation for taking leave); the district court granted Crete summary judgment on all claims.
On appeal the Eleventh Circuit reviewed de novo whether Jarvela was a "qualified individual" under the ADA and whether Crete violated the FMLA by not reinstating or by retaliating.
The court held that (1) DOT regulations place the employer, not the DOT medical examiner, with final responsibility to determine whether a driver has a "current clinical diagnosis of alcoholism," and Crete properly determined Jarvela was disqualified; (2) Jarvela’s FMLA interference claim failed because Crete showed it would have fired him regardless of leave; (3) the retaliation claim failed for lack of causal connection/actual knowledge.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Jarvela was a "qualified individual" under the ADA	Jarvela argues he was qualified and a DOT medical examiner implicitly cleared him by issuing a 6‑month certificate	Crete argues Jarvela had a current clinical diagnosis of alcoholism and employer must ensure DOT qualifications	Employer bears final responsibility to determine DOT qualification; Crete permissibly found Jarvela disqualified
Who decides if a driver has a "current clinical diagnosis of alcoholism" under DOT regs	Jarvela: only a DOT medical examiner can make that determination	Crete: employer must make the final determination under 49 C.F.R. § 391.11(a)	Court: DOT places onus on employer; employer may disagree with medical providers and decide
FMLA interference — right to reinstatement after leave	Jarvela: Crete denied reinstatement in violation of FMLA	Crete: would have discharged Jarvela upon learning of his diagnosis regardless of FMLA leave	Crete presented unrebutted evidence it would have fired him regardless; interference claim fails
FMLA retaliation — causal connection to protected leave	Jarvela: timing and personnel access show causal link	Crete: decisionmaker lacked actual knowledge of FMLA leave; timing alone insufficient	No evidence decisionmaker knew of protected leave; temporal proximity alone is insufficient; retaliation claim fails

Skop v. City of Atlanta, 485 F.3d 1130 (11th Cir. 2007) (standard of review for summary judgment)
Pritchard v. Southern Co. Serv., 92 F.3d 1130 (11th Cir. 1996) (ADA prima facie elements)
Earl v. Mervyns, Inc., 207 F.3d 1361 (11th Cir. 2000) (employer written job description as evidence of essential functions)
Garcia v. Vanguard Car Rental USA, Inc., 540 F.3d 1242 (11th Cir. 2008) (interpretation principles for unclear regulatory language)
United States v. Cuomo, 525 F.2d 1285 (5th Cir. 1976) (definition of term of art in legal interpretation)
Martin v. Brevard Cnty. Public Schools, 543 F.3d 1261 (11th Cir. 2008) (employer defense to FMLA reinstatement: would have discharged regardless)
Strickland v. Water Works and Sewer Bd. of City of Birmingham, 239 F.3d 1199 (11th Cir. 2001) (standard for FMLA interference)
Krutzig v. Pulte Home Corp., 602 F.3d 1231 (11th Cir. 2010) (temporal proximity insufficient without decisionmaker's actual knowledge)
Access Now, Inc. v. Southwest Airlines Co., 385 F.3d 1324 (11th Cir. 2004) (issue preservation / waiver on appeal)