Sakari Jarvela v. Crete Carrier Corporation
776 F.3d 822
| 11th Cir. | 2015Background
- Jarvela sued Crete Carrier under the ADA and FMLA after being terminated as a commercial motor vehicle driver.
- Crete terminated Jarvela based on a Bradford Health Services diagnosis of alcohol dependence issued a week before termination.
- District court granted summary judgment for Crete on all claims, including ADA and FMLA claims.
- The panel held Jarvela’s ADA claim hinged on whether he was a “qualified individual” under DOT standards, specifically the no current clinical diagnosis of alcoholism.
- Evidence showed Jarvela had a current diagnosis of alcoholism (Bradford letter, Concentra exam, and treating physician’s notes) at the time of termination, supporting nondiscrimination under DOT rules.
- The court affirmed summary judgment for Crete on all claims, concluding Jarvela could not satisfy the DOT qualification standards.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ADA qualification per DOT standards | Jarvela argued no current diagnosis at termination. | Crete relied on a current diagnosis under DOT §391.41(b)(13). | No; Jarvela had a current diagnosis, so not qualified. |
| Interference with FMLA rights | Crete would have reinstated him but for leave; denial violated FMLA. | Crete would have discharged anyway regardless of FMLA leave. | AGAINST Jarvela; interference claim fails. |
| FMLA retaliation | Termination tied to FMLA leave. | No causal connection; no knowledge of leave. | From lack of actual knowledge, no causal link; retaliation claim fails. |
| Causation standard for FMLA retaliation | Temporal proximity proves causation. | Need actual knowledge; timing alone insufficient. | Requires actual knowledge; summary judgment affirmed. |
Key Cases Cited
- Pritchard v. Southern Co. Serv., 92 F.3d 1130 (11th Cir. 1996) (prima facie ADA elements; qualified individual)
- Martin v. Brevard Cnty. Pub. Schools, 543 F.3d 1261 (11th Cir. 2008) (FMLA interference standard; but not satisfied here)
- Krutzig v. Pulte Home Corp., 602 F.3d 1231 (11th Cir. 2010) (causation requires actual knowledge of FMLA leave)
- Skop v. City of Atlanta, 485 F.3d 1130 (11th Cir. 2007) (summary judgment de novo with favorable inferences)
- Lucas v. W.W. Grainger, Inc., 257 F.3d 1249 (11th Cir. 2001) (affirming summary judgment on grounds supported by record)